Roundtable on Sustainable Palm Oil - Home | US...2. Jambi : Kol.Pol. M.Thaher Street, RT 33 RW 10...

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Roundtable on Sustainable Palm Oil Annual Surveillance Audit Report Report no.: ASA2_ 106473 Surveillance assessment against the RSPO Principles & Criteria 2008 PT Bakrie Sumatera Plantation Jambi Unit PT Agro Mitra Madani Palm Oil Mill PT Agrowiyana Plantation Jambi Province Date of assessment: 12 to 14 August 2014 Report prepared by: Aswan Hasibuan (RSPO Lead Auditor) Certification decision by: Muhammad Bascharul Asana (Managing Director of TUV Rheinland Indonesia) Certification Body: TUV Rheinland Indonesia Menara Karya 10th Floor Jl. H.R. Rasuna Said Block X-5 Kav. 1 – 2 Jakarta 12950 – Indonesia Phone: +62 21-579 44 579 Fax: +62 21-579 44 575 Email: [email protected]

Transcript of Roundtable on Sustainable Palm Oil - Home | US...2. Jambi : Kol.Pol. M.Thaher Street, RT 33 RW 10...

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Roundtable on Sustainable Palm Oil

Annual Surveillance Audit Report Report no.: ASA2_ 106473

Surveillance assessment against the

RSPO Principles & Criteria 2008

PT Bakrie Sumatera Plantation Jambi Unit

PT Agro Mitra Madani Palm Oil Mill PT Agrowiyana Plantation

Jambi Province

Date of assessment: 12 to 14 August 2014 Report prepared by: Aswan Hasibuan

(RSPO Lead Auditor)

Certification decision by: Muhammad Bascharul Asana

(Managing Director of TUV Rheinland Indonesia)

Certification Body: TUV Rheinland Indonesia Menara Karya 10th Floor

Jl. H.R. Rasuna Said Block X-5 Kav. 1 – 2 Jakarta 12950 – Indonesia

Phone: +62 21-579 44 579

Fax: +62 21-579 44 575 Email: [email protected]

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TABLE OF CONTENTS

1.0 SCOPE OF ANNUAL SURVEILLANCE AUDIT 3

1.1 National Interpretation Used 3 1.2 Type of Assessment 3 1.3 Certification Details 3 1.4 Location and Maps 3 1.5 Organisational Information / Contact Person 5 1.6 Description of Supply Base 5 1.7 Actual production volumes, tonnages and projected outputs. 6 1.8 Dates of Plantings and Replanting Cycles 6 1.9 Area of Plantation (Total, Planted and Mature) 6 1.10 Progress Against Time Bound Plan 7 1.11 Compliance to Rules for Partial Certification 7 1.12 Progress of associated smallholders or outgrowers towards RSPO compliance 8 1.13 (Revised) Approximate Tonnages Certified 8

2.0 ASSESSMENT PROCESS 9

2.1 Certification Body 9 2.2 Qualifications of Lead Assessor and Assessment Team 9 2.3 Assessment Methodology & Agenda 10

3.0 ASSESSMENT FINDINGS 12

3.1 Summary of Findings 12 3.2 Status of Previously Identified Non-conformities 24 3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions 24 3.4 Noteworthy Positive Components 38 3.5 Issues Raised by Stakeholders and Findings Pertaining to Issues 46

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL

RESPONSIBILITY 47

4.1 Date of Next Surveillance Visit 47 4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client 47

APPENDICES 48

Appendix 1: Details of Revised Certificate (if applicable) 48 Appendix 2: List of Abbreviations 48 Appendix 3: List of Stakeholders Interviewed and Contacted 48 Appendix 4: Observations and Opportunities for Improvement 49

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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1.0 SCOPE OF ANNUAL SURVEILLANCE AUDIT

1.1 National Interpretation Used

The operations of the palm oil mill(s) and its supply base of FFB were assessed against the Indonesia national Intepretation year 2008 of the RSPO Principles & Criteria.

1.2 Type of Assessment

The 2nd annual surveillance audit was carried out on 1 mill and 1 estate, PT BSP’s Jambi unit, which include

of PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyana Plantation owned by PT Bakrie Sumatera Planta-

tion Tbk.

The date of certification of this unit was August 08, 2012 .

1.3 Certification Details The details of RSPO certification of PT Agro Mitra Madani Palm Oil Mill and PT Agrowiayana Plantation are as per the table below

Table 1: RSPO Certification details of PT Agro Mitra Madani Palm Oil Mill and PT Agrowiayana Plantation

1.4 Location and Maps

Table 2: GPS locations for all estates and mills in cluded in annual surveillance assessment

Name of mill / es-tate

Location GPS locations

Latitude Longitude

PT Agro Mitra Madani Mill

WKS Main Street KM.11, Tebing Tinggi Village, Tungkal Ulu Subdistrict, Tanjung Jabung District

1.040 S – 1.120S 103.080 E –103.120 E

PT Agrowiyana Es-tate

WKS Main Street KM.11, Tebing Tinggi Village, Tungkal Ulu Subdistrict, Tanjung Jabung District

1.040 S – 1.120S 103.080 E –103.120E

RSPO Membership no.: 0036-07-000-00045-07(O)

RSPO Certificate no.: 18501949001

Date of first RSPO certificate & validity: 2012-08-28 to 22017-08-287

Date of certification audit: September 19 to 23, 2011

Date of previous surveillance audit: 15 to 18 July 2013

Date of revised RSPO certificate & va-lidity (if applicable):

No revised certificate

CPO tonnages claimed: 22,097 Mt

PK tonnages claimed: 5,282 Mt

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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Source : HCV Assessment document from Pollito Consulting

Figure 1: PT Agrowiyana Plantation and PT Agro Mit ra Madani Mill in Jambi Province, Indonesia

Figure 2: Map of PT Agrowiyana Plantation

PT Agrowiyana & PT Agromitra Madani Mill

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RSPO Annual Surveillance Audit Report

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1.5 Organisational Information / Contact Person

Contacts details of the company are as follows:

1.6 Description of Supply Base

PT Agro Mitra Madani (AMM) mill is one of the palm oil mills that is owned by Bakrie Sumatera Plantation

in Jambi. PT AMM mill was established in 2001 with installed production capacity 60 tonnes/hour in ac-

cordance with the legal regulations ‘Keputusan Badan Penanaman Modal dan Promosi Daerah (BPMPD)

or the Decision of Board of Investment and Regional Promotion - Jambi Province No.

15/07/1/PMDN/2001 (March 20, 2001) ’. Currently, PT AMM mill receives supplies from one company-

owned estate, smallholder schemes with total smallholders members of 4576, independent outgrowers

and trading, as described below. Composition of FFB supply is company owned estates: 40. smallhold-

ers scheme 59% and independent outgrowers: 1%.

Table 3. FFB Supply Information for PT Agro Mitra M adani for year 2012 to June 2013

FFB Contributors

FFB supplied Tonnes (Jan-Dec 2013)

FFB supplied Tonnes (Jan-July 2014)

Tonnes % Tonnes %

Company owned estates:

PT Agrowiyana (PT AGW) 96,811 40,10 44,967 30.50

Sub Total Company owned Estate

96,811 40,10 44,967 30.50

Others supplier

Other company’s area (Plasma) 143,568 56.47 78,442 53.21

Outgrowers 1,036 0.43 24,020 16.29

TOTAL 241,433 100 147,429 100

Company Name : PT Agro Mitra Madani Mill and PT Agrowiyana Plantat ion

Address : 1. Jakarta : Complex of Resuna Epicentrum Bakrie Tower, 18th -19th floors, HR Rasuna Said Street – Jakarta Province 12960

2. Jambi : Kol.Pol. M.Thaher Street, RT 33 RW 10 No.1A/2A Tambak Sari Village, Jambi Selatan Subdistrict – Jambi District

3. Mill: WKS Street KM.11, Tebing Tinggi Village, Tungkal Ulu Subdis-trict, Tanjung Jabung Barat District, Jambi Province

Contact Person : Efdy Ruzali

Vice Leader RSPO Group Bakrie Sumatera Plantation

Telephone : 1. Tel : 021-29941286-87, Fax : 021-29941752

2. Tel : 0741-35334, Fax : 0741-26338

3. Tel : 0741-35334, Fax : 0741-26338

Email : [email protected] ; amm@ bakriesumatera.com /[email protected]

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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Certified CPO and PK still not claimed as certified , company has not contract yet for CSPO and CSPK cl aim.

1.7 Actual production volumes, tonnage and projecte d outputs.

Table 4: Certified tonnages claimed, certified tonn ages purchased or sold, total and projected CPO and PK production from PT Agro Mitra Madani.

*) data from January – December 2013 consist of from material certified and material non-certified. **)data realization production from own estate.

1.8 Dates of Plantings and Replanting Cycles The company follows a replanting cycle of 25 years. Information on the dates of plantings are as per the table below. Table 5: Age and year of plantings of company estat e supplying to PT Agro Mitra Madani

Age & Year of Plantings Oil palm planted area at each estate(ha)

I II III IV V VI TOTAL

0 - 5 yrs (2009 – 2014) 0.00 0.00 0.00 0.00 0.00 0.00 0.0

5-10 yrs (2004 – 2008) 0.00 12.42 0.00 3.05 545.70 0.00 561.17

10-15 yrs (1999 – 2003) 12.15 123.68 3.02 321.98 86.15 49.70 596.68

15-20 yrs (1994 – 1998) 720.08 656.35 790.00 496.85 131.03 465.40 3,259.71

20-25 yrs (1989 – 1993) 0.00 0.00 0.00 0.00 0.00 0.00 0.0

25-30 yrs (1984 - 1988) 0.00 0.00 0.00 0.00 0.00 0.00 0.0

TOTAL 732.23 792.45 793.02 821.88 762.88 515.10 4,417.56

No planned and actual oil palm replanting activities for PT Agrowiyana Plantation have been carried out

since all planted area of the estates are still below 20 years old. The company’s first replanting program is

planned in year 2017 for the oldest area of the estate.

1.9 Area of Plantation (Total, Planted and Mature)

Table 7 : Oil Palm Planted Area Summary, FFB Production and Average yield/ha for PT Agrowiyana Plan-tation

Estate Name Total area

(ha)

Oil Palm Planted area

(ha)

Mature (Production)

area (ha)

Immature (Non-production)

area (ha)

FFB Production

(tonnes)

Average yield/ ha

Amount (MT) Year 2013 Amount (MT)

Until July 2014 CPO PK CPO PK

Certified tonnages claimed 22,097 5,282 22,097 5,282 Certified tonnages sold* - - - - Certified tonnages purchased* - - - - Actual Production* 47,967 10,464 29,964 6,542 Actual certified production** 18,044 3,939 9,908 2 ,216

Projected output for next 12 months - - 31,766 6,3 44

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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Agrowiyana plantation

4,686 4,417.56 4,417.56 - 103,674 23.46

TOTAL 4,686 4,417.56 4,417.56 - 103,674 23.46

Table 8 : Land use data for PT Agrowiyana Plantation

Estate Name Total area (ha)

Oil Palm

Planted Area (ha)

HCV &

Potential HCV ar-eas (ha) *

Land used for other purposes (ha)

Local

Government office

Nursery Cleared

Area Other Land

Agrowiyana Plantation

4,686 4,417.56 225 12 23.82 78.23 154.53

TOTAL 4,686 4,417.56 225 12 23.82 78.23 154.53 Note: * Potential HCV area due to a part of plantation area is depth peat soil > 3 m and has been planted

1.10 Progress Against Time Bound Plan PT Bakrie Sumatera Plantation Tbk as holding company has revise their time bond plan, due to several planta-tion unit has been unconsolidated with BSP, the new timebound plan as seen as table below. Table 7: Time Bound Plan of the Other Management Un its

Name of Holding Location Time bound plan for certification

BSP Kisaran Kisaran, North Sumatera Certified

Agrowiyana Jambi Certified

Bakrie Pasaman Plantation* Pasaman, West Sumatera Certified

Graha Dura Leidong Prima North Sumatera 2014

Indogreen Central Kalimantan 2015

1.11 Compliance to Rules for Partial Certification

Compliance of the uncertified management units of PT Bakrie Sumatera Plantation against the rules for partial certification according to RSPO Certification System clause 4.2.4 was assessed by Review self assessment re-port submit by company to TUV Rheinland. A summary of findings is as stated below.

Partial Certification Requirements Audit Findings

(a) The parent organization or one of its ma-jority owned and / or managed subsidiaries is a member of RSPO.

The parent organization of PT Agromitra Madani and PT Agrowiyana plantation is PT Bakrie Su-matera Plantation Tbk. With RSPO member no 1-0036-07-000-00045-07(O)

(b-d) A challenging time-bound plan for certi-fying all its relevant entities is submitted to the Certification Body (CB) during the first certification audit. The time-bound plan should contain a list of subsidiaries, estates and mills.

Any revision to the time-bound plan or to the

PT Bakrie Sumatera Plantation Tbk has revised the time bound plan as determined on the table above. The revision due to some of company’s under Su-matra Plantation Group has been sold to others plantation company.

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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circumstances of the company shall cause the plan to be reviewed. for whether it is still appropriate, such that changes to the time-bound plan are permitted only where the or-ganisation can demonstrate that they are justified

(e) No replacement of primary forest or any area identified as containing High Conserva-tion Values (HCVs) or required to maintain or enhance HCVs in accordance with RSPO criterion 7.3. Any new plantings since Janu-ary 1st 2010 must comply with the RSPO New Plantings Procedure

According to information from BSP Management, there is no no replancement of primary forest or any area identified as containing High Conserva-tion Values (HCVs).

(f) Land conflicts, if any, are being resolved through a mutually agreed process, e.g. RSPO Grievance procedure or Dispute Set-tlement Facility, in accordance with RSPO criteria 6.4, 7.5 and 7.6.

According information from BSP Management and interview with local communities surrounding com-pany’s area, they have good relationship and there were no conflict appears relating to land dispute.

(g) Labour disputes, if any, are being re-solved through a mutually agreed process, in accordance with RSPO criterion 6.3.

No labour dispute in PT bakrie Sumatera Plantation Group.

(h) Legal non-compliance, if any, are being resolved in accordance with the legal re-quirements, with reference to RSPO criteria 2.1 and 2.2.

Some legal compliance are identified,this is be-come non conformities for each plantation unit, such as under report Kisaran Palm Oilo Mill, PT BSP Unit North Sumatera.

1.12 Progress of associated smallholders or outgrow ers towards RSPO compliance

The company has no planning for smallholder or out grower toward RSPO compliance, this is raised non conformities as explaince on the section RSPO Certification Requirement 4.2.3 pages 56.

1.13 Approximate Tonnages Certified The approximate tonnages certified shall be the same as per the original certificate, which is as follows Crude Palm Oil (CPO) : 22,097 tonnes Palm Kernel (PK) : 5,282 tonnes

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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2.0 ASSESSMENT PROCESS

2.1 Certification Body PT TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent test-ing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. PT TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Validations and Verifications. PT TUV Rheinland Indonesia’s office is located in Jakarta.

2.2 Qualifications of Lead Assessor and Assessment Team The assessment team members of this surveillance audit that were part of the same assessment team for the certification audit are as follows: 1.Aswan Hasibuan 2.M. Fundy Kurniawan 3. Doni New assessment team members that were not part of the previous assessment team are as per the table be-low:

Name Position Qualifications / Experience

Aswan Hasibuan

Lead Au-ditor

Education : Industrial Engineering – University of Sumatera Utara . Indone-sia, (1991 to 1998) Training attended: Lead Auditor untuk ISO 9001:2000 – TUV Rheinland;

pelatihan lead assessor ISO 14001 – TUV Rheinland; Lead Auditor train-

ing OSHAS: 2007 di TUV Rheinland Indonesia, Ahli K3 Umum, Coating

Inspector by Indocor & LIPI

Working experience: Professional industry 1999-2004, Quality Managemnet Consultant (2004-2009), Lead Auditor for QMS, EMS, and OHSAS dat PT TUV Rheinland Indonesia. Auditor RSPO and ISPO (2011- pre-

sent)

Doni Auditor

Education: Master Degree in Rural Sociology, Bogor Agriculture University Training attended: Susatainable Forest Management, Workshop for up-grading of Susatainable Forest Management, Technical assisstance for rural farmers, Jurnalistick training. Work experience: Experienced in RSPO auditor, Sustainable Forest Man-agement auditor, free lance on National Development Planning Agency of Indonesia, free lance on State Minister for Accleration Development Back-word Regions, free lance on Ministry of Public Work, in 2006 – 2007 work fro JICA and UNDP

M. Fundy Auditor

Education: Master Degree in Natural Resource and Environmental Man-agement, Bogor Agriculture University Trainings attended: Environmental Impact Assessment (EIA), Ecological Risk Assessment (ERA), Internal Quality Audit Training for Quality Manage-ment System, IRQA-QMS ISO 9001:2000, High Conservation Value (HCV), RSPO Lead Auditor Course, ISPO Auditor Course, Timber Legality Verifica-tion (SVLK) Working experience: Experienced in Environmental Impact Assessment, En-vironmental Health Safety Senior Officer (EHS-Officer) in Wilmar International Plantation, Internal Auditor for Wilmar International Plantation, Auditor for Rountable on Sustainable Palm Oil (RSPO), Indonesian Sustainable Palm Oil (ISPO), Certification for Timber Legality Verification (SVLK) in PT TUV Rhein-land Indonesia since June 2012 – present.

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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2.3 Assessment Methodology & Agenda The 2nd surveillance assessment was conducted betwen August 12 – 14, 2014 as per the assessment pro-gram below. The assessment was carried out in accordance with PT TUV Rheinland Indonesia’s RSPO audit procedure as well as the RSPO Certification Systems document. During assessment, the qualified TUV Rhein-land assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without com-promising the integrity of the assessment in anyway. All 1 estates and 1 mill were visited and the assessment team carried out field and document assessments of compliance to all the RSPO principles and criteria. Common systems were identified and specific evidence was recorded for individual estates. Interviews were conducted at all estates and the mill. The company proposed the correction and corrective action for all identified non conformities raised to the cer-tification body 30 days after the closing meeting. Verification of closure of major non-conformances was con-ducted 2 months after the closing meeting of the main assessment by document checking, which is proposed by auditee and implementation of corrective actions for minor non-conformities will be verified during the next suriveillance audit. The 2nd surveillance audit agenda is as explained below.

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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2nd Surveillance audit Agenda

Date Location/ Main sites Main activities

12.08.2014 PT AMM Mill

Verification previous audit finding • Opening Meeting. • Introduction of team members and assessment agenda • Presentation from Bakrie Sumatera Plantation Unit Jambi management • Document review from all aspects • Checks of documents and relevant mill include EIA, SIA & OSH docu-ment • Document of legal compliance : legal company and equipment li-censes

12.08.2014 PT AGW • Plant tour to the whole area of POM to checking the implementation of PPE, OHS and waste handling

• Interviews with mill workers from engine room, wastewater treatment plant, security post, tractor driver, and workshop.

• Checking of chemical stores and hazardous waste stores • Document of legal compliance : legal company, legal permit, and legal

boundaries. • Company’s management plan: long term business plan and forecast ex-

traction OER, information financial, and forecast prices (prices FFB and CPO) .

• Social Aspect Document Review & SIA document • Conflict Resolution Procedure, Procedure of Handling Complaints, HCV’s,

Wages, List of Stakeholder, List of Contractors, Health & clinic

PT AMM Mill

SCCS

13.08.2014 PT AGW • Environmental and social aspect document review • Legal compliance : legal company, legal permit (HGU), legal boundaries

and permit of equipment. • Labour union, female worker, health & clinic. • EIA, SIA, OSH. Procedure Communication, Conflict Resolution Procedure,

Procedure of Handling Complaints, HCV’s, Wages, List of Stakeholder, List of Contractors.

• Interview with female sprayers/maintenance workers, and Division 5 of-fice’s estate.

• Children’s crèche, housing, barn owl boxes, washing area for chemical spraying equipment at Division 2 estate.

Company’s management plan : long term business plan and crop projec-tion (FFB yield trends), information financial, and forecast CPO’s prices

14.08.2014 PT AGW • Environmental aspect: energy efficiency, waste & water management

• Continue review of document

• Environmental : chemical and fertilizer store, river buffer zones, peat planted areas and water subsidence monitoring points

• Closing Meeting

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RSPO Annual Surveillance Audit Report

PT Agro Mitra Madani Palm Oil Mill and PT Agrowiyan a Plantation – Jambi

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3.0 ASSESSMENT FINDINGS

3.1 Summary of Findings The following is a summary of findings during this surveillance audit for the criteria listed in the RSPO Princi-ples & Criteria Indonesian National Interpretation year 2008.

Principle 1: Commitment to transparency

Criteria assessed: CR1.1, CR1.2 Criteria not assessed: - Findings: The company are consistently record any requests for information from various parties (stakeholders). As for the recording notes in a log book is available either in the estate or in the factory. Company respond to any incoming requests for information. Company will response through reply letter. Proposals or in-coming mail will be reviewed by Communication dept Head, before submitted to to Area Head for the de-cision taken. In some cases, head of public relation discuss with any relevant party for carification and consideration for decision-making process.The company has mechanism for communication and consul-tation i.e. No. AG-BC-R-24, Rev. 1 dated September 27, 2013. Records for incoming request of infor-mation, wiill be keep maintain by the clerk Estate, clerk CA / CSR (external) and HRD (Internal) for 5 years.. Until 2nd survailance, company still consistently records any requests for information from various parties (stakeholders). The records are available at the estate office and factory it is recorded on the log book. The recording includes information related parties, the date, the name / external agencies, response, the completion date, status and description. Some explample was taken such as: 1) Incoming letter from the Talang Makmur village, about the petition to get land certificate on March 15, 2014, No. Letter 140/499 / Pem-TLM / 2014, , addressed to head of PT Agrowiyana. 2) Letter from the district. Of Tebing Tinggi regarding Development Planning Meeting (Musrembang ) On February 13, 2014, # 400/096 / PMD, the letter addressed to the Top Management of the PT Agrowi-yana. 3) Letter from Murky River village No. 140/177 / Gov / 2013 Intended To PT Agrowiyana On January 25, 2013, asked for donation. 4) Letter from Police Tungkal Ulu letter No. 08 / III / 2013 / Reskirim Intended To PT Agrowiyana, on 2 June 2013., Notice of progress investigation Results. Coordination meeting will be conducted everymonth to evaluate monthly company’s performance, at-tended by all departments head and regional head or public relation head as the chairman. Records all icomng request of information were stored properly in inbox file. Request of information from external parties were recorded in a log book, the book consist information about, letter number, date, subject, e.g. The company established documented procedure for provision of feedback information contained in the Procedure of Communication, Consultation and Participation No. AG-BC-R-24, Rev. 1 dated September 27, 2013. Based on the memo from management on September 10, 2011 No. 55 / CA-Legal / JMB / IX / 2011, publicly available documents i.e. location permit, plantation licenses, land use right(HGU) certifi-cates, Document Environmental and Social Impact Analysis (EIA / UKL, UPL), Document social activities and community relations, occupational health and safety program, partnership program, mission and vi-sion statements and document continuous improvement program Based on the memo from management on September 10, 2011 No. 55 / CA-Legal / JMB / IX / 2011, some documents that publicly available are: 1. License Documents (location permit, plantation licenses, certificates HGU. 2. Environmental and Social Impact Analysis (EIA / UKL, UPL) Documents 3. social activities and relationships with the community Document the 4. Occupational Health and Safety Program 5. The partnership program 6. The mission and vision statements 7. Document continuous improvement program Document of compliance to legal, laws regulation also available.

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Compliance status: Full Compliace

Principle 2: Compliance with applicable laws and re gulations

Criteria assessed: CR2.1, CR2.2, Criteria not assessed: CR2.3 Findings: During the 2nd surveillance, lot of evidence that company has taken efforts to fulfil government regula-tion, however the company has not complied yet with some regulations and this was raised as non con-formities.

Bakrie Sumatera Plantation (PT Agrowiyana plantation and PT Agro Mitra Mandani mill) has a list of ap-plicable legal and other requirements documented under “List of Laws and Regulations” (“Daftar Pera-turan & Perundang-undangan”) dated February 2014 (Form AG-SMM-P-S-03). The management has a mechanism for ensuring that compliance with relevant legal requirement is implemented related environ-mental i.e. SOP number: AG-SML-P-S-01. A documented system about legal requirement that company should comply related to occupational safety and health are determined on procedure number: AG-SMK-P-S-01 and AG-SMK-P-S-0 (list of OHSAS regulations and laws), company also has a procedure for evaluation compliances to applicable legal regulation for other issues as determined on AG-SMM-P-S-01 rev.03.

Result of evaluation of company’s compliances to applicable legal regulation and other requirement can be seen on document of “Evaluations of compliance to applicable local, national dan ratified international laws and regulation”. As stated on the procedure point 6.4.5 that all departments must evaluate their compliances to applicable legal and other requirement at least once a year. Last evaluation was con-ducted on February 2014.. However at the audit time, some applicable legal and other requirement still not included on the list and not evaluated its compliances I,e. The company can not show the mechanism/program to fulfil the 19 law and reagulation is still no compliance based on record of law and regulation evaluation. This is raised as non conformity. The company’s land operation in Tanjung Jabung District Jambi province has 6 certificates of right to use the land as explained on the previous audit report. There is no changes until 2nd surveillance audit. While the land use righ certificate, the company has licenses for operation both for plantation and mill that still valid until nowsuch as: • Agrowiyana plantation has a plantation business permit (Ijin Usaha Perkebunan/IUP) No. HK.350/540/DJ.BUN.5/VII/2001. • Agro Mitra Madani mill has a plantation business permit (Ijin Usaha Perkebunan/IUP) No. 729/Kpts/HK.3.50/Dj/Bun/IX/2001. Estate boundaries are clearly identified and demarcated on the field. The condition of lagal boundary are visible maintained such as boundary stone between company’s area with farmers in the village Brasau (SP1) and other estate PT MAKIN. HGU stakes conditions at the site are well maintained. As seen on the report of boundary stones on July 2014. It was verified aslo by the auditor team in Division IV-3 Block-4 are cleary maintained. The progress of land conflict between company and communities such as: Land disputes in KM.8 by H. Zaini BR but based on the judges ruling PN Kuala Tungkal (No. 06/Pdt.G/2010/PN.Ktl, dated on January 6, 2011) that lawsuit cannot be accepted. The decision was read on January 13, 2011 at the court public hearing which was attended by lawyers from both parties. Conflicts are resolved based on the company’s mechanism. The other conflict is between company and Harun CS who claime 47 ha land. This is ongoing land conflict which is still under court process. Until June 2014, the land conflict still not resolves. Some negotiation has been conducted while waiting for the resoulution from the court. Based on the land claims case, the company chose to use the land through legal channels, because the plantation land acquisition has been completed. The Company has completed the land issue with the relevant stakeholders including through compensation payment or called “sago hatit”. There is evidence that company tried to solve the conflict through participatory method. Compliance status: Non Compliance

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NCR No. 2014 – 01 of 04 The company can not show the mechanism/program to fulfil the 19 law and reagulation is still no compliance based on record of law and regulation evaluation.

Principle 3: Commitment to long-term economic and f inancial viability

Criteria assessed: CR3.1 Criteria not assessed: - Findings: During the 2nd surveillance audit, both PT Agrowiyana plantations and PT Agro Mitra Madani mill have management plans (budget and strategic plan) for a 5-year period (2013-2017). Among others, infor-mation on company activities available on this document included Total Revenue, Total Operating Cost, profit/loss before and after tax. The company has a financial schedule for yearly budget. Information con-tained in the document includes general plantation routine operational activities such as field mainte-nance, harvesting, fertilizer application, investment plans such as enrichment planting (planting of various plant species to enhance biodiversity), while mill activities/data include fresh fruit bunches (FFB) pro-cessing, projected oil extraction rate (OER) and kernel extraction rate (KER). Company has clear and de-tail planning information for RKL/RPL (Environmental management and monitoring plan) activities and management and monitoring plans for social impact and HCV. It was verified budget document for opera-tional activities such as mill and estate operational and non operational activities asuch as General & Af-fair expenses activities, including budget for environmental monitoring, safety compliances, maintenatnce program, social issues for year 2013, for next 3 year all activities has been included and increase 10% every year. And, based on area statement data and work plan budget for 5 years, there is no replanting activity programmed by the company. Compliance status: Compliance

Principle 4: Use of appropriate best practices by g rowers and millers

Criteria assessed: CR4.1, CR4.2, CR4.3, CR4.4, CR4. 5, CR4.6, CR4.7, CR4.8 Criteria not assessed: - Findings: During the 2nd surveillance audit, both of the PT Agrowiyana Plantation and PT Agro Mitra Madani has standart operating procedures (SOP’s) from land clearing actvity, planting oil palm, fertilizer application, spraying, pest integrated management system’s, harvesting, FFB delivery, grading, reception of FFB, dipatch of CPO and PKO, and during the surveillance audit all of the SOP’s still valid and no changes there’s SOP’s. Both company, has a operational record and maintaned very well for the estate and mill such as FFB de-livery records, FFB grading reports and process daily reports. To ensure the monitoring of operation complie with the procedure, the company already conducted man-agement review on January 28, 2014 and February 14, 2014. The managemet reviewed discussed about the achievement company to implementation system such as Procedure’s, ISO 9001, 18001 and RSPO. Based on managemet report, both of the company has made efforts to complie the system very well. But it was found, two (2) procedures, about grading. When both of procedure mentioned different sam-pling process for grading. First procedure (Form.No.AG-SMM-WI-L-02 Rev 04) mentioned that the grad-ing through the 100 FFB sample (this procedure is obsolete), but the second procedure (Form.No.AG-SMM-WI-L-02 Rev 06) no mentioned about sample, but every truck form own estate or smallholder in-coming should be grading (still valid). When the checking on the loading ramp, the grading officer con-ducted the grading through the 100 sample of FFB. So, this grading activity if refer to company procedure no complie with valid procedure, and this is as minor non compliance. During the 2nd surveillance company already conducted the leaf analyis in 2013, for fertilizer recommen-dation 2014, evidenced by record result of leaf analysis reference number 314/RD/EXT/L/OKT/13, date of issued 16/10/2013, with total 66 sample, parameter analyzed is Ash, N, P,K, Mg, Ca, B. For soil analysis, company conduct every 5 years, with the lastes soil analysis conducted on September

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2010, by Soil Laboratory, Land Resources, Agriculture Departement. The company already record of efforts to maintain and increase soil fertility through the: a. Fertilization activity, example:

- MOP fertilization in Division V date on 22/07/2014, record from werehouse expenditures number 05598, fertilizer distribution for field number C35 as 474 kg's. And based on foreman daily report on the same date, the MOP fertilizer application has been done.

- Urea fertilization in Devision II date on 07/07/2014, record from werehouse expenditures number 05117, fertilizer distribution for field number B21 with area 38 Ha, 4,822 trees, as 9.644 kg's, and application daseg is 2 kg/tree. And based on foreman daily report on July 11, 2014, the urea fer-tilizer application has been done with total tree application is 3,274 or 12.89 Ha. Next, on July 15, 2014 the estate continious for urea fertilizer application for shortage for fertilizer application before.

- Kieserite fertilization in Division I date on July 11/2014, record from werehouse expenditures number 05574, fertilizer distribution for field number C09 with total tree is 2,676 tree, as 1,338 kg's, dosage application is 0,5kg/tree. And based on foreman daily report on July 11, 2014 the kieserite fertilizer application has been done for all tree.

b. EFB application in 2014 until July for all division based record of EFB program and application, estate already done applicate of EFB for all division with achievement ralization from the plan, example: - Division I, plan application 4,950,000; until July 2014, has been application as 3,189,320 or

64.43% from the plan; - Division II, plan application 5,018,400; until July 2014, has been application as 2,924,095 or

58.27% from the plan; - Division III, plan application 5,460,000; until July 2014, has been application as 5,576,540 or

102,13% from the plan; c. Land application, until July 2014, the company has realized example for:

- April 2014, total land application is 11,941 m3, - Mei 2014, total land application is 10,850 m3 - June 2014, total land application is 13,471 m3

All application is compliance with the permit. During the 2nd surveillance audit, based on soil map, EIA document and soil survey conducted by Primakelola Consulting, there are some area with peat soil in the PT Agrowiyana, with the depth peat var-iation from: < 50 cm (oxisol gelick), 50 – 100 cm (organosol sapric), 100 – 200 cm (organosol sapric), 200 – 300 cm (organosol sapric) and > 300 cm (organosol sapric). Based on soil survey information the orga-nosol sapric with depth > 300 cm is a peat with category Typic haplohemist or organosol hemic. So, based on information above, type of peat in the company is varied. Based on the peat soil scale 1:50,000 peats with > 300 cm depth located in field number F11, E13, D11, D13, D15, and D17. Based on soil map and EIA document, the company does not have land with highly slope, the topography condition is flat with slope is about 0 – 8%. The company already program for road maintenance throug the budget plan for road maintenance such asa main road, production road, collection road, and increased the road quality for 2014. The company also concduct road maintenance, example:

- record of request for heavy equipment type greader for division IV date on 17/02/2014 for road compaction, and has been done realized as 15,5 km.

- record of request for heavy equipment type greader for division II date on 14/05/2014 for collec-tion road maintenance, and has been done realized as 21.9 km.

The company has a procedure with document number Form.No.AG-SMM-WI-E-36 Date Issued Septem-ber 26, 2011 about the work instruction water level management on the peat soil. On the work instruction water level measurement data collecting is every day with water level acceptable is 50 cm until 75 cm. The company also has procedure number Form.AG-SMM-WI-E-37 Date Issued September 26, 2011 in the procedure was state about measurement procedures for subsidence level on the peat soil use PVC pipe for measuring instruments and collecting data is every six month. Then, based on information form soil survey, type of peat soil depth in the company i.e.: 1. < 50 cm is about 20 Ha (0.41%) 2. 50 – 100 cm is about 301 Ha (6.18%) 3. 200 – 300 cm is about 380 Ha (7.80%) 4. > 300 cm is about 225 Ha (4,63%) During the 2nd surveillance audit, the conducted the measurement of water management program with data daily collecting. Water management for peat soil. Based on record of water level measurment, there is no water level for peat soil is under than standard, and the company has efforts to maintain the water

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level when the wheater condition is not supported such as, dry seasone. During the 2nd surveillance audit, the company already protected their riparian bufferzone through the reforstation activity in along of riaprian buffer zone with Sungkai cultivation, no chemical activity in ripari-an bufferzone, and also conduct for water analysis. The company already implemented of water management plan, such as:

- For riparian bufferzone, the company not allowed to chemical activity in along of riparian, not al-lowed for illegal fishing, and others activity will be contaminate the river.

- For peat land, the company already conduct the water level measurement, drainage, subsidence level, and daily record for water level and check for drainage water level condition.

To ensure the water quality, the company already conduct water quality analysis, every semester through the record of testing result report conducted by Environmental Quality Control Laboratory of PDAM Tirtawening Kota Bandung, example for:

- Testing result report number 4.751.304.027 smpling from downstream and number 4.751.304.028 from upstream of Berasau river, analyzed date on June 12-30, 2014, accordance to Government Regulation Number 82/2001, there is no identified paramaters higher than standart.

- Testing result report number 4.751.301.021 smpling from inlet WTP and number 4.751.301.019 from upstream of outlet WTP, analyzed date on June 12-30, 2014, accordance decree of Minis-try of Health number 416/Men-Kes/PER/IX/1990, there is no identified paramaters higher than standart.

- Testing result report number 4.751.301.023 smpling from ground water-housing well, analyzed date on June 12-30, 2014, accordance decree of Ministry of Health number 416/Men-Kes/PER/IX/1990, there is no identified paramaters higher than standart.

During the 2nd surveillance audit, the company also conduct the BOD monitoring effluent, example: a. Daily BOD monitoring, accordance to report of POME monitoring April-June 2014 period, there is

no BOD parameter is higher than standart, when the standart is 5,000 mg/l. b. Montly BOD monitoring, according to the report analysis number:

- 014/LHU/L2JBI/I/14 date of analysis January 7-24, 2014 BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bodies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

- 143/LHU/L2JBI/II/14 date of analysis February 18, unti March 6, 2014, BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bod-ies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

- 237/LHU/L2JBI/III/14 date of analysis March 18 until April 1, 2014, BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bod-ies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

- 334/LHU/L2JBI/IV/14 date of analysis April 15 until May 12, 2014 BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bodies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

- 449/LHU/L2JBI/V/14 date of analysis May 16 until June 16, 2014 BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bodies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

- 609/LHU/L2JBI/VI/14 date of analysis June 24 until July 11, 2014 BOD paramater is under than standart, conducted by UPTB Environmental Laboratory of Environmental Regional Bodies fo Jambi Province, also analysis for others parameter, such as pH, BOD, COD, TSS, N-total, Grease and Oil, Cd, Cu, Pb, and Zn.

The company already record of water monitoring use per tonne of FFB for 2013 and 2014 until July. a. For 2013, total water use 689,248 m3, consist of (for process 369,619 m3; boiler 194,154 m3

and domestic 125,475 m3). Next, for process, water use per tonne FFB is: - January 1,39 liter/tonne FFB - February 1,26 liter/tonne FFB - March 1,80 liter/tonne FFB - April 2,13 liter/tonne FFB - May 2,28 liter/tonne FFB

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- June 2,19 liter/tonne FFB - July 1,46 liter/tonne FFB - August 1,26 liter/tonne FFB - Sept 1,31 liter/tonne FFB - Oct 1,39 liter/tonne FFB - Nov 1,25 liter/tonne FFB - Dec 1,53 liter/tonne FFB - Average 1,53 liter/tonne FFB

b. For 2014, total water use 510,419 m3, consist of (process 341,745; boiler 93,170; domestic 75,504). Next, for process water use per tonne FFB is: - January 2,47 litter/tonne FFB - February 2,26 - March 2,46 - April 2,33 - May 2,44 - June 4,10 - July 1,94

During the 2nd the company already program for PHT in 2013 and 2014. Actual and realization based on program is complie with 100%. Example for Division I, with total area 732.23 Ha for all pest. The company already has record monitoring for Early Warning System census, examaple for division 1, field number C07, based on EWS on 25/03/2014 it was found caterpillar attack with heavy categorized, and the company followed by fogging to control the caterpillar attack. After the fogging, estate conducted the mortality census to ensure the caterpillar population. Based on record of EWS mortality census date on 25/05/2014 for field number C07, the caterpillar population has been decreased. The company already conducted training for EWS person who responsible for EWS census evidenced by photograph of field training on May 20, 2014 for all division attended by 6 person. For PHT, the com-pany also use beenficial plant and natural predator to control the pest, such as:

- Turnera subulata. Company planted the turnera in along of field/block. Example for division III, until 2013, turnera cultivated is 3,640 meter or 226.46 Ha.

- Antrigonon leptopus. Company also planted the antigonon. this plant just cultivated in division IV. - Tyto alba. Company also breed the Tyto alba as natural predator to control the mice. Example

until July 2014, in division III, it was recorded 9 individu Tyto alba has mature and out from the owl box. The company also has map of owl box for all division.

The company was use the chemical registered based on Pesticides Book issued by Pesticides Commis-sion, Directorate General of Estate, the Ministry of Agriculture of Indonesia 2012. But the company does no recommendation chemical used from the Ministry of Labor c/q Labor and Transmigration offices asso-ciated with the use of chemical in the workplace (refer to CR 2.1 major). The company have documentation a policy for commitment to reduce/ eliminate the chemicals categorize from WHO and Rotterdam Convention, this document was sign by Mr. H. Ahmad Najib as General man-ager, and already realization for chemical application, the company was applied to reduce the chemical from 1A and 1B WHO and Rotterdam convention, based on record of chemical used i.e.: round up,

1. Budget record in 2013 for circle spraying only 0.10 litter/Ha paraquate and in budget record in 2014 for circle spraying was 0.05 litter/Ha. If refer to record of monitoring chemical use in 2013 to 2014 (June) showed that the chemical used is reduced based on budget.

2. Record of supplier purchase order summary period of July 2013 till July 2014, there is no transac-tion for chemical ordered included the paraquate

The company has planned to perform medical checkup periodically for all workers who related with agro-chemicals for 2014. For pregnant and breastfeeding medical checkup, company informed to the clinic for brief to all workers if they have in pregnant and breastfeeding they must report to the clinic. The company also gave the announcement with memo number 022A/EH-INTI/I/2012 on January 2nd. 2012 which con-tains information about for sprayer if their have pregnant condition in order no carry out work related to chemicals, (still valid) But based field observation and interviews with employee, they understood very good if they have preg-nant or breastfeeding they do no to work related to chemical, and the company delivered they to manual working. Company has policy for occupational safety and health, signed by the Operations Director. The company

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also has a Sustainable Palm Oil Policy, signed by the President Director dated May 6, 2013, among which implement Health and Safety Management System (OHSAS 18001:2007) at each operating company. Procedures and work instructions related to Health and Safety has been created for the Laboratory area (AG-SMK-PL, AG-SMK-WI-L), process / plant (AG-SMK-PP, AG-SMK-WI-P), and workshop POM (SMKPW- AG, AG-SMK-WI-W). Health and safety related work on plantations, are listed on the Work Instruction Estate (AG-SMK-WI-E). The Company has Procedure for Preparedness and Emergency Response No. form. AG-SM-R-23 rev. 02 dated March 3, 2009 and Emergency drill already performed in April 10th, 2014. Identified emergencies that may occur in the company is due to fires, accidents, pollution / Hazardous Material leaks, natural dis-asters (floods and earthquakes), and public demonstrations/riots. There is an organization structure Preparedness and Emergency Response PT BSP Tbk Unit Jambi. The company already put many safety sign including “No Smoking” sign at many places around the office, la-boratory, workshop, oil tank and mill and effectively implemented by workers. No smoking policy at identified place has stated in Perjanjian Kerja Bersama (PKB) between PT Agrowi-yana-AMM (Agro Mitra Madani) and Management of Work Unit, Plantation Workers Union Federation of All Indonesia Worker Union (PUK SPP P F SPSI) PT Agrowiyana-AMM year period 2013-2015, signed on March, 4, 2013 article 50 (1.4) “Kriteria Pelanggaran, and about punishment stated in Chapter IX Pem-binaan Disiplin article 51 Ketentuan-ketentuan umum”. There is a brief report of use of fire extinguisher (APAR) for Emergency and response team (ERT team), held on April 10th, 2014, simulating emergency and response (Anti Fire Coordination Board) and the pre-vention of work accidents, held at the plantation area. Company also determine all contractor to fulfill health and safety regulation during they working time in whole company area, as determine in working contract as per contract no : SPK No: 035/SPK-AMM/IV/2013 between PT Agro Mitra Madani with CV. Afftersindo Maju Sejahtera. Company also provide OHS equipment and first aid equipment at worksites and ensure trained workers f first aid available at that workplaces. Company provide accident insurance for All workers in accordance with evident of insurance payment for 724 workers in May 25th, 2014. The Insurance covering benefit of Accident, Pension, and Life Insurance. For the regular health examination to all workers exposed to high risk work, the company already pre-pared name and time for examination. The record of regular health examination was kept. Like engine room operator, and the examination will be held in the end of August, 2014. It was found that the company has training program for all workers in the estate and mill to identify what does the training need for every level position and training target,. Example: Integrated Pest Control Man-agement for foremen, Sterilization and sanitation Training for sprayer, Training of Effective Manuring, Safety Electricity, Fire-fighting, first Aid training for foremen and more. Example refreshment training for sprayers and for workers related with agro-chemical, was done in April 2014 held by EHS Officer and pesticides supplier. Etc. For the contractor, the company has requirements for contractor, when the requirement is the contractor must have competence example driver contractor must have licensed for drive, etc. Then, company has record for Contractor Agreement both of PT Agrowiyana and PT Supra Surya (as contractor) number SPK 012/SPK-AGW/IVI/2014, in clause 4 about “Rights and Obligation” stated that the contractor must provide the heavy equipment operator with a licensed, and professional mechanical as a requirement for operator. Compliance status: No Compliance NCR No. 2014 – 03 of 04 1. It was found two precedures of FFB grading i.e. Procedure No.AG-SMM-WI-L-02 Rev04 has been

obsolete mentioned about requirement for sample FFB are 100 pcs per incoming truck, while the re-vised procedure .No.AG-SMM-WI-L-02 Rev06 (valid) mentioned about every truck from own estate and smallholder should be sample. It was sight during the audit, grading officer still conduct the grad-ing process referenced to obsolete procedure..

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Principle 5: Environmental responsibility and conse rvation of natural resources and biodiversity

Criteria assessed: CR5.1, CR5.2, CR5.3, CR5.4, CR5. 5, CR5.6 Criteria not assessed: CR5.6 Findings: There is no changes for EIA document (AMDAL) for both company, they still using the same document, the EIA document was issued in Jakarta in 1996 and was signed by the Ministry of Agriculture Number 112/ANDAL/RKL-RPL/BA/X/1996 on October 24, 1996. The company has record of regular reporting of EIA document to Environmental Bodies evidence by: 1. Receipt of delivery RKL-RPL (environmental of management and monitoring) period of January –

June 2014 (Semester 1) was delivered to environmental bodies of Jambi Province with delivery rec-orded On August 8th, 2014

2. Receipt of delivery RKL-RPL document in semester I to Environmental Bodies of Tanjung Jabung Barat Regency on August 8th, 2014

3. Receipt of delivery RKL-RPL document in semester I to Environmental Bodies of Jambi province on August 8th, 2014

4. Receipt of delivery RKL-RPL document in semester I to Environmental Bodies of Regional Sumatera in Pekan Baru on August 8th, 2014

This report contain analysis of : 1. Report of analysis Number 143/LHU/L2JBI/II/2014 about the measurement monitoring of POME

analyzed on February 18th, until March 06th, 201, and the result is within the standard required. 2. Report of analysis Number 334/LHU/L2JBI/IV/2014 about the measurement monitoring of POME

analyzed on April 15th, until May 12th , 2014, and result is within the standard required. 3. Report of analysis clean water from the water treatment plan unit number 2 based on Decree of Min-

istry of Health Number PermenKes 416/MENKES/PER/IX/1990 with the number report analysis No: 4.751.301.021, date of analyzed June 12th – June 30th 2014, and result is within the standard re-quired.

4. Report of raw water from Giring-giring River number 4.751.304.030 conducted on June 12th – June 30th 2014 with the result is within the standard required, based on Government Regulation Number 82/2001

5. Report of emission analysis number 4.751.303.030 conducted by Laboratorium engendalian Kuali-tas Lingkungan PDAM Tirta Wening on June 12th – June 30th, 2014 based on Decree of Ministry of Environmental number Kepmen LH Kep 07/2007 the result is within the standard required

1. Report of noise number 4.751.301.206 conducted on June 12th – June 30th 2014, , based Decree of Ministry of Environmental number 48/1996 and Decree of Ministry of Labor and Transmigration number Kep-51/1999 about the required standard for noise in workplace. Based on analysis result there are 6(six) workstation indicated is upper than standard, and the company was follow up by re-quiring the workers to use the PPE

During the 2nd surveillance audit, there is no change on company’s HCV document, company still using the documents that made by external consultant last year 2010 as well as documents for HCV manage-ment and monitoring plan. According to the exisiting HCV document there are 5 types of HCVs were identified in 6 estates is HCV 1.1, 4.1, 1.3, 1.4 and 2.3 (peat area (> 3 m), Riparian zone (Baung river, Brasau river, Giring-giring river, Sianang river), POM’s reservoir (B01), riparian river and watercouses, springs (B02 & D09), and conservation forest (B01 & B03). In the report was identified the protected spe-cies, rare, threatened or endangered, i.e.: 1. Gracula religiosa Cites appendix II 2. Felis bengalensis Cites appendix II 3. Lutra sumatrana Cites appendix II 4. Presbytis melalaphos, IUCN Endangered and Cites appendix II 5. Macaca nemestrina, IUCN Vulnerable and Cites appendix II 6. Macaca fasicularis Cites appendix II 7. Pyhton molurus Cites appendix II 8. Pthyon reticulatus Cites appendix II 9. Varanus salvator Cites appendix II During the 2nd surveillance audit, the company not yet conduct monitoring, measurement, preserve for flo-

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ra and fauna included to IUCN and CITIES appendix II accordance to HCV report. This raise again as a non-conformities. But, the company during the 2nd surveillance the company already monitoring and management HCV every semester. There are available record of report monitoring and management, example:

- Report monitoring and management HCV semester I (January - June, 2013), with activity have been done is: cultivation of turnera, pohon sungkai in riaprian bufferzone as 20 trees, HCV brief for workers on January 17, 2013, maintenance for HCV signboards and added new signboard in riparian bufferzone.

- Report monitroing and management HCV semester II (July - December, 2013), with activity have done is: installation of subsidence for peat land, reforestation for riparian bufferzone, HCV moni-toring (include vegetation monitoring for reforestation plant in riaprian bufferzone; species moni-toring). But no evidenced for record of species monitoring, ilegal fishing, ilegal hunting, and oth-ers.

The company already conducted process for protected species and ilegal hunting, ilegal fishing and ilegal activity related to HCV management plan and law and regulation. The evidenced is report of monitoring and management plan of HCV for 2013 in semseter I and semester II.

- Report monitoring and management HCV semester I (January - June, 2013), with activity have been done is: cultivation of turnera, pohon sungkai in riaprian bufferzone as 20 trees, HCV brief for workers on January 17, 2013, maintenance for HCV signboards and added new signboard in riparian bufferzone.

- Report monitroing and management HCV semester II (July - December, 2013), with activity have done is: installation of subsidence for peat land, reforestation for riparian bufferzone, HCV moni-toring (include vegetation monitoring for reforestation plant in riaprian bufferzone; species moni-toring)

The company already installed signboard, poster, and warning for protected species in estate and mill ar-ea. Company already install as 59 signboard, consist of: - 13 signboard for ilegal hunting in all devision - 1 signboard for wellspring bufferzone protected area - 16 signboard for riparian bufferzone protected area - 12 signboard for ilegal fishing - 8 signboard for warning burn - 1 signboard for restricted area - 1 signboard for environmental protection - 7 signboard for conservation area Company also conduct HCV brief for all workers in January 17, 2013 evidenced by photograph and at-tendant list, attended by 22 person. The company already training for HCV responsible person on April 4-8, 2011. And this person responsible for HCV management, evaluation of HCV management implementation, and others. For the hazardous waste management, the company has collect the hazardous waste from the all Division in the estate, then all the hazardous deleverd and kept in to the Central Store, after all the hazardous col-lected, the central store delivered to the hazardous warehouse licensed in mill, the delivered times is al-most 2 month, based on recorded delivered i.e.: 1. Record delivered number 00236 Form AGW-FR-03-Rev 00 on June 11, 2014 delivered 6 litter oil to

hazardous warehouse licensed in mill from Division 4 2. Record delivered number 01003 Form AGW-FR-03-Rev 00 on June 12, 2013 delivered 4 litter oil to

hazardous warehouse licensed in mill from Division 4 3. Record delivered number 00797 Form AGW-FR-03-Rev 00 on June 14, 2013 delivered 11 litter oil to

central store from Genset house in Division 2 The hazardouse above stored in central store, and delivered on July 8th, 2014 with form delivered AGW-FR-03-Rev00. From the hazardouse collected process until delivered to warehouse licensed in mill is al-most 2 month (see criteria 2.1.1)

The company has record of energy use energy per ton CPO or per ton FFB. Based on record of analysis energy used in 2014 until July, recorded:

- Shell production is 6,044 tonne, and used as 2,657 tonne or 44.0% - Fiber production is 18,982 tonne, and used as 18,982 tonne or 100% - And energy analysis used if converted to solar used are 0,57liter/tonne FFB, with energy

used/ton FFB is 21,780 MJ/tonne FFB, equivalent litter solar used per ton FFB is 544 litter so-lar/tonne FFB.

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Company has zero burning policy, not to use fire for preparing land for replanting. This policy signed by Mr. H. Ahmad Najib as General Manager dated on November 15th, 2010 and still valid. Fire is not a choice for Company in this matter. Till today company don’t have replanting activity. Procedure of emergency responses to land burning is available, (AG-SMK-WI-E-06) and company pro-vide some appropriate equipment of fire extinguishers and facilities. Company also train personnel who responsible to use this equipment.

Company has document about source of GHG emission for PT AMM such as effluent pond, EFB storage, operation machines, boiler operation, FFB and CPO transportation, chemical material storage. Company’s planning to reduce GHG emission is methane capture as CDM program however, due to financial prob-lem, management decide to postpond the program. Company change their program to reduce pollution and emission through saving energy through saving diesel and electric consumption as seen in PT Agro-mitra Madani palm oil mill and PT Agrowiyana estate source of emission was the usage of fertilizer, re-duce of chemical usage, to keep waster surface in peat-lands, land application of POME, and planting conservation trees. The company has a list of identification of pollution and emissions sources, Compliance status: Non Compliance NCR No. 2014 – 4 of 4 1. The company establish document for HCV management, however until the 2nd survaillance audit

there is no evidence of HCV management plan implementation, especially for monitoring and measurement of flora and fauna as mentioned on HCV report (CITES Appendix II and IUCN).

Principle 6: Responsible consideration of employees and of individuals and communities af-fected by growers and mills

Criteria assessed: CR6.1, CR6.2, CR6.3, CR6.4, CR6. 5, CR6.6, CR6.7, CR6.8, CR6.9, CR6.10, CR6.11 Criteria not assessed: 6.8 Findings: The existing environmental impact document approved by the government still used. As required all iden-tified social and environmental impact were managed and monitored every 6 monIt was sight report of management and monitoring plan for periode January to June 2014. .

The report covers the management of job and business opportunities, the management of the public rev-enue enhancement and management of public perception. Report of the management and monitoring of the social environment that has been done by the company has included the negative impact that may be caused by plantations and factories

The realization of social impact management: 1. Public facilities (infrastructure) and social facilities 2. Empowerment of farmers 3. Employment opportunities 4. Opportunity Endeavor 5. Conflict land The company conduct social impact assessment program for period from January to June 2014. Follow-ing the realization of the management of social positive impacts as following: 1) Provide heavy equipment (greder) for Makmur village office. 3) Provide assistance for transportation for villager of Kuala Dasal. 5) Maintenance of boundary markers. Company has good relationship and communication with communities surronding estate area. The company still use Environmental managent and monitoring plan from year 2006. There are some changes in company’s activities compare with year 2006 condition, however there is no document revi-sion for RPL / RKL of PT Agrowiyono Plantation and Mill PT Agro Mitra Madani. This is potential for im-provement, to ensure that Environemntal management and monitoring plan were periodoc maintain. Company has cooperation with smallholder program, however this smallholder still not include in RSPO certification since the agreement is in progress for settlement. Some of activiries regarding smallholder scheme:

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(1) Brief of P&C RSPO in 6-8 August 2009, (2) Traning for smallholder for implementing proncip and criteria RSPO based on office of Agriculture Department Budget of Jambi Province dated on 4-6 August year 2010. The company still uses procedure for communication and consultation with the community, (AG-SM-R-27 year 2013). the company has many records of communication meeting held with smallholder/outgrower on 2012 to 2013 years. The SOP was made with participatoruy method. . Based on SOP’s above the company has a record documentation of consultation and communication with community and related stakeholders through the log book and maintaned very well. But this SOP was compiled without involve of communities and related stakeholders. Company also has list of related stakeholders, the information consist of profile of stakeholders from government,all villager, local army, local cooperation local clinic in the village, contractors and supplier also listed in the list of stakeholder. The record of communities aspiration and its responses were keep maintain as observed on the logbook, e.g. aspiration from Purwodadi villager on January 15th, 2014 regarding proposed of soft loan to PT Agrowiyana, and it was responsed by company throuh letter even the company can not fulfill the re-quest. Company assign 2 person who has responsible for consulting and communicating according to the letter decree number 033/BUH/BSP-JBI.I/II/2012 and number 279/HRD/BSP-JBI.I/AGW/V/2012. The procedure SOP AG-SMM-P-S-02-Rev00 for identification and calculation of fair compensation still same with the main audit, no changes the SOP, and the procedure was introduced to stake holder through the meeting and accepted by the affected parties. The company has records for incoming complain handling. It was observed on the log book, a compliant from the worker dated on January 7, 2013 from Division 7, housing number 6A and 6B about regarding broken facility. During the audit it was sight company was responsed and repair the door as rquested by the worker. Company has procedure for conflict resolution regarding land dispute and claim i.e. SOP AG-SMM-P-S-02 Rev. 01 year of 2013. The mechanism for compensation was calculated after result of field checking, the company will make negotiation to the land claimer and compensation calculation will be done together between company and claimer under supervision by local government. The mechanism for identification, calculation and compensation of loss of legal or costumary rights of land with involvement of local com-munity representatives and relevant agencies SOP AG-SMM-P-S-01 2011 similar with previous audit pro-cedure. Negotiation process for compensation payment will be recorded on compensation agrements that will be signed by both parties. Example is documentation for compensation for Dagang villager in year 1993 this payment was docu-mented by the letter agreement and photograph. . Ths minimum wage in 2014 based on the Decree of the Governor of Jambi Province No. 610 / Kep.Gub / DISOSNAKERTRANS / 2013 Province Minimum Wage ( UMP ) Jambi 2014 is Rp . 1,502,230.00 ( one million five hundred and two thousand two hundred and thirty dollars ) . The monthly salary structure for company’s employees consists of basic wages , overtime , premium , enterprise -hour load , rice allow-ance , while every year the permanent worker also will get ied fitri Incentive, and bonuses . Based on the observation of a document summary list of salary payment in June , 2014, all employees received wages above the minimum wage in 2014. The company owns Document Collective Labour Agreement ( CLA ) between PT Agrowiyana - AMM with the PUK . SPP . F. SPSI . PT Agrowiyana- AMM Year Period 2013-2015 Example for determination of minimum salary, wage profision for daily labour was meeting with the law and regulation. Based on document observasion and interview with some employees in June 2014, all employees has minimum salary more than Provice Minimum Wage year 2014. Example :: 1) Staff for working at HOFD, daily employee, salary paid in June 2014 Rp. 2,105,000. 2) Staff for working at HOHRD, daily employee, salary paid in June 2014 Rp. 2.820.000. Salary component consist of: wage, overtime, accident insurance allowance, tax allowance, rice allow-ance, housing maintenance, health insurance allowance, and premium. Company provide sufficient housing for all employees, however, some of house need to be repaired. Company also provide clean water for all employees and their family. Company require all the supplier and contractor to comply with labor regulation and others regulation. Base on document observasion, company enforce their supplier to fulfil related regulation consistently and made it in working contract agreement, for example: 1) Working Contract Number 021/SPK-AMM/VI/2014 between PT Agro Mitra Madani with CV Fadhilla, for

service power pack presson. In the contract clause state that Second Party (CV Fadhilla) has to pro-

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vide PPE, fulfill requirement related to Occupational Health and Safety and pay for Value Added Tax. PT Agro Mitra Madani already paid CV Fadhilla amount Rp. 44.673.750. (fourty four million six hundred and seventy three thousand seven hundred and fifty rupiahs)

2) Working Contract Number 014/SPK-AMM/IV/2014 between PT Agro Mitra Madani with contractor for generator set machine rent. In the contract clause state that Second Party has to protect environment, use PPE and to fulfill requirement related to Occupational Health and Safety. PT Agro Mitra Madani al-ready pay for him amount Rp. 59.400.000(fifty nine million four hundred thousand rupiahs) The company still consisten with ther policy for freedom of association for workers. There are a worker union in PT Agrowiyana and Agromitra Madani and was approved by the Head Labour and Transmigra-tion. There is regular internal meeting records among workers union to discuss about revised working agremement between company and the workers for period year 2013-2015 dated September 17, 2013 at-tended by 34 participant, meeting on November 8, 2013 attended by 26 participant. During the audit, company has no changes their is policy about the workers age requirement, and still same with the main audit, when standart for worker is should be above 18 years old and was meet with the law and regulation. It was not sight both in the filed and employee data July 2014 , there is no under-age worker both in the estate and in the mill. The company does not change their policy about the sexual harassment and violence, and still consisten to implement the policy for all activity in the estate and mill. This policy was documented in the signboard and available in housing and office. Based on field observation in sprayer workers they understood that the policy and they know where to report it. The company also has policy about the protection of repro-ductive rights, and this policy still same and there is no changed. Company brief the workers and employees regarding mechanism or procedure of to avoid sexual har-rasment in morning muster and place some signboard in strategis location, sucha as field office, main of-fice and mills so employee easy to read. For example: June 6th, 2014 briefing of anti sexual harassment in Estate attended by 7 person. FFB price for Smallholder was decided by Local Agriculture Officer of Jambi Province Prov. Jambi every wee, while FFB price for other third party was decided by Marketing office Medan following with interna-tional FFB market price. Officially the price will be informed to Cooperative and third party representa-tiove. There are working agreement between company and its suppliers, the Working Agreement consists of scope of work, time frame, cost of work, and term of payment. The agreement was proofen fair, legally, and transparent by signing by company and contractor. It was confirmed through payment documents that company always pay ontime. Company has contribution to local development as: 1) Smallholder development: 7 Cooperative, 171 farmer group, 4.576 farmer, 7.700,89 ha. 2) Charity for Eid Mubarak 2014 submitted to local community around plantation amount Rp.

37,500,000.00 3) Maintenance of smallholder main road at SP-3 Sukadamai Village, sub-district Tebing Tinggi, dated on

April 30th, 2014. 4) Budget for CSR in 2014 Rp. 173,375,000.00 5) Income tax June 21st, 2013, PT Agrowiyana Rp. 3,216,317.00 6) Vehicle tax of Heavy equipment SKP Number 973/04/PKB-AB/2014 s/d Number 973/10/PKB-AB/2014

dated May 16th, 2014 amount 7 (seven) unit Rp. 4,342,900.00 7) Surface water tax and land period of January to February year 2013 amount Rp. 1,311,380.00 paid by

Bank Mandiri at Jambi. 8) Road Lighting tax Pajak penerangan non-PLN year 2013 amount Rp. 7,482,264.00 paid by Bank Man-

diri in Jambi. Compliance status: Compliance with observation

Principle 7: Responsible development of new plantin gs

Criteria assessed: CR7.1, CR7.2, CR7.3, CR7.4, CR7. 5, CR7.6, CR7.7 Criteria not assessed:

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Findings: The company has no new development area program. The company’s first planting took place in year 1993 for an area of 659.00ha and completed plantings in year 2005 for an area of 274.83ha. As there are no new plantings, this requirement is not applicable. According to the estate’s AMDAL document prepared in 1996, the area within the company’s ‘Ijin Perlepasan’ (Release permit) covering an area of 13,000ha had no primary forest but only secondary forest classified under ‘Hak Pengusahaan Hutan’ (Forest Development Rights) and vegetation in the forms of wild bushes and other types of commercial and non-commercial vegetation. Compliance status: Not Applicable

Principle 8: Commitment to continuous improvement i n key areas of activity

Criteria assessed: CR8.1 Criteria not assessed: - Findings: Overall implementation of plans is defined based on risk level evaluated for identifying significant as-pects. Verified & cross checked implementation of the actions such as waste management control, chemical management control, etc. During surveillance audit the proposed corrective actions from last RSPO audit are not well implemented, it was sight similar non confirmities.

There is no improvement plans were established for year 2012 and 2013 since company has financial problem. Even in the field auditor team found a lot of potential improvement in key areas and activities. All similar non conformties has been raised again. Compliance status: Non Conformities see revelan NCR on Principle 1 to 6

RSPO Certification Requirement No 4.2.3

Findings: Program for smallholder certification in preparation. Compliance status: Non compliance

3.2 Status of Previously Identified Non-conformitie s For the previus surveillance assessment, a total of 29 nonconformances were identified. These consisted of 21 major non-conformities and 8 minor non-conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the assessment, and this was verified by the audit team through document that submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the closure of these minor non-conformities will be assessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

Criterion 2.1.1 (Major) Evidence of compliance with relevant legal requirements

NCR No. 2013 – 01 of 29; Major

1. There is found that the hazardous waste was delivered more than the 90 days based on manifest record December 17, 2012 and April 18, 2013 (raise again as a non conformities).

2. There is found that license for CV Surya Jaya as hazardous waste transportation had not valid

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during the surveillance audit. 3. It was found the record of hazardous waste from central store to licensed hazardous warehouse

is almost 2 month, where the central store did not have a license for hazardous waste storage. 4. There is found that the agrochemical in the estate does not have recommendation licensed from

Labour and Transmigration Head Offices (related to CR 4.6.1) 5. There is found that the operator for heavy equipment is not valid when they work. 6. There is found that the contractor workers of CV AMS is under age 7. There is no found evidence for proof of payment for work insurance (JAMSOSTEK) for all worker

in April, May and June 2013 (related to CR 4.7.1) Correction:

1. The company has already licensed extend permit for retention time for hazardous waste with let-ter of permit for retention time of hazardous waste number 660/551/BLH on June 24, 2013 Issued in Kuala Tungkal from Environmnetal Bodies Offices Regency of Tanjung Jabung Barat, with new retention time is 180 days, and valid from issued.

2. The licensed of hazardous waste transportation for unit transport of BH 8419 AO has already ex-tend permit with letter number SK.2910/AJ309/DJPD/2013/150710344BB-0001 from Ministry of Transportation, Directorate General of Road Transportation and valid until May 7, 2014, and for transportation unit number BH 8535 MK has already extentio permit with letter number SK.2910/AJ309/DJPD/2013/150710344BB-0002 from Ministry of Transportation, Directorate General of Road Transportation and valid until May 7, 2014

3. The company has already internal memorandum about retention time of hazardous waste date is-sued on August 28, 2013, state that the retention time for hazardous waste on central store max-imal in 7 days.

4. The company has already delivered letter number 384/PRSN-BSP/JBI/VIII/2013 on August 2nd, 2013 about request for registered of chemical used in work place to Head Offices of Labour and Transmigration of Tanjung Jabung Barat Regency, and has receipt evidence on August 04, 2013 (related to CR 4.6.1)

5. The company has already extend the licensed for heavy equipment operator, and was valid until July 2018.

6. The company has already termination of employment under age based on record Number SK.122/HRD-AMS/VII/13 on July 19, 2013, and the contractor has a comitmen for wokers under 18 years old based on letter statement on July 18, 2013.

7. The company has payment for work insurance (JAMSOSTEK) for all workers in April, Mei and June 2013 based on evidence of proof payment by bank transfer.

Corrective Action:

1. The company has commitment to ensure the hazardous waste was delivered to collector licensed maximal in 180 days, and the company was change they hazardous collector licensed from CV Surya Jaya Logam to PT Bintang Mas Cahaya International based on agreement letter Number SPK.103/AMM/AH/VIII/2013.

2. The company has commitmen to ensure that the unit for hazardous waste transport is always val-id for traportation by checking the licensed and if found the licensed is almost not valid, the com-pany will be send a letter or email or telephone to the collector to extend the licensed.

3. The company has commitmen to ensure that the hazardous waste from division to central store is only 7 days maximal and after that will be delivered to hazardouse warehouse licensed.

4. The company has already delivered letter for registered they chemical used and ensure that all chemical in the company was registered in Pesticides Comission Book and Head of Labour and Transmigration of Tanjung Jabung Barat Regency

5. The company has already extend the licensed for heavy equipment operator and ensure that all of operator has valid licensed

6. The company will ensure that all of internal workers and workers from contractor is above 18 years old.

7. Because the company has economic efficiency program and economic problem, so they can not pay out the JAMSOSTEK. Next, the company will be ensure that they implemented of JAMSOSTEK Regulation and Regulation of Employment

Auditor Conclusions: Closed Verification result;

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1. Company already sent their hazardous waste inline with their permit (within 90 days) and has ap-pointment with collector to collect in regular time

2. Collector already renewing their license. Company has mechanism to check all related document when collector come to take hazardous waste such as; transportation permit and vehicle number

3. Company already has policy not keep hazardous waste more than one week in central store. 4. All agrochemical which is stock by company was registered and has license from Labor and Transmi-

gration Head Offices 5. The company has already extend the licensed for heavy equipment operator and ensure that all

of operator has valid licenced 6. The company will ensure that all of internal workers and workers from contractor is above 18

years old, ther is no under age employee. 7. company has no outstanding payment for work insurance (JAMSOSTEK) for all workers in Mei ,

June and July 2014 based on evidence of proof payment by bank transfer Date of closure: September 4 th, 2013

Criterion 2.1.2 (Major) Evidence of efforts made to comply with changes in the regulations

NCR No. 2013 – 2 of 29 There is found that the regulation update is not complie with the company SOP’s AG-SMM-P-S-03 Rev 01, page 3 ponit 6.2.4. Correction: The company has already assign responsibility to DCC (document control central) for update law and regulation in page 3 of procedure AG-SM-R-26. And the company has already withdrawal of not valid law and regulation from the list of law and regulation document. Corrective action: The company will be ensure that all of law and regulation update is meet with they procedure and every update the company will be provide the evidence. Auditor Conclusions: Closed Verification result: During the 2nd surveillance audit, the company already update regulation an in-line with Procedure of Regulation Requirment and Others (AG-SM-20) Date of closure: September 4 th, 2013

Criterion 2.2.2 (Minor) A mechanism to resolve conf lict which is accepted by all parties

NCR No. 2013 – 3 of 29 There is no record of the SOP of conflict resolution be accpeted by the communities and others stake-holder. Correction: The company has socialize their SOP about conflict resolution and was accepted by all parties evi-dence by minutes of meeting and was signed by all stakeholders Corrective action: Documentation for mechanism of grievence and conflict resolution and ensure that all of the problem related to grievence and problem resolve is refer to this SOP and should be documented. Auditor Conclusions: Closed

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Verification result: Company showed evidence the SOP of conflict resolution be accpeted by the communities and others stakeholder by showing briefing record. Date of closure: September 4 th, 2013

Criterion 3.1 (Major) There is an implemented manag ement plan that aims to achieve long-term economic and financial viability

NCR No. 2013 – 04 of 29 Theres is no found record for fertilizer application in 2012 based on budget fertilizer in 2012 (related to CR 4.2.2 minor) Correction: The company has submit the correction for fertilizer application. In budget 2011 the company was alocat-ed budget for fertilizer application, but there is no realization because the company carry out the eficiency budget in 2011, so in 2012 to replace the fertilizer application the company applicated the compost fertiliz-er based on Letter number 42/CEP/Jkt/X/2011 on October 21st, 2011 about the recommendation fertilizer in 2012, state for PT Agrowiyana, fertilizer compost application is for 4,000 Ha area’s with dosage is 10 tonne/Ha. And the company was realized compost application for 4,000 Ha areas’s based on memo num-ber AH-BSP/JBI/I/2012 on January 2nd, 2012 about the compost application. Corrective Action: The company will be ensuring the fertilizer application is based on recommendation and situation of the company. Auditor Conclusions: Closed Verification result: During the 2nd surveillance audit, the company already done for fertilizer application. Based on record fer-tilizer application, and budget, company has committed to fertilizer application. Date of closure: September 4 th, 2013

Criterion 4.2.1 (Minor) Records of regular soil, le af, and visual analysis

NCR No. 2013 – 05 of 29; Minor There is no found the record of leaf analysis periodically for 2012 Correction: The company has conducted the leaf analisys in 2012, based on correction leaf analisys record in 2012 for Jambi Area 1, PT Agrowiyana. Corrective action: The company will ensure periodically leaf analysis every year. Auditor Conclusions: Closed Verification result: During the 2nd surveillance audit, the company already conduct leaf analysis for 2012, total sample is 66 block sample, with parameter analyzed is N%, P%, K%, Ca%, Mg%, B ppm. For 2013, company has been conduct leaf analysis with reference number 314/RD/EXT/L/OKT/13, date of issed 16/10/2013, with total 66 sample, parameter analyzed is Ash, N, P,K, Mg, Ca, B. Date of closure: September 4 th, 2013

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Criterion 4.2.2 (Minor) Records of efforts to maint ain and increase soil fertility (e.g. the use of fertilizer, legume cover crops, compost, and land a pplications of POME or EFB) based on the results of analysis carried out as in Point 1 above NCR No. 2013 – 06 of 29; Minor Fertilizer recommendation in 2011 for urea application is about 10,123 kg’s but in 2012 there is no found record of realization for this fertilizer. Correction: The company does not realized the urea fertilizer application in 2012 because the company has carry out eficiency budget in 2011, so fertilizer applied changed to the fertilizer compost based on Letter number 42/CEP/Jkt/X/2011 on October 21st, 2011 about the recommendation fertilizer in 2012, state for PT Agrowiyana, fertilizer compost application is for 4,000 Ha area’s with dosage is 10 tonne/Ha. And the company was realized compost application for 4,000 Ha areas’s based on memo number AH-BSP/JBI/I/2012 on January 2nd, 2012 about the compost application. Corrective Action: The company will be ensure the fertilizer application is based on recommendation and situation of the company. Auditor Conclusions: Closed Verification result: During the 2nd surveillance, company has been done the fertilizer application. Based on record of plan and fertilizer realization it was mention:

- Urea, have applied as 334,500 kg’s from the plan as 558,905 kg’s - MOP, have applied as 47.500 kg’s from the plan as 363,203 kg’s - Kieserite, have applied as 49.400 kg’s from the plan as 60,809 kg’s

Date of closure: September 4 th, 2013

Criterion 4.3.4 (Minor) Subsidence of peat soils sh ould be minimised under an effective and documented water management programme.

NCR No. 2013 – 07 of 29; Minor There is no found that the water management on peat land no represent for all depth peat on the compa-ny (raise again as a non conformities) Correction: The company has submit for correction for program installation of water level sampling, water table and subsidence location. Based on map of work program, water level, water table and subsidence will be installation on file numbe B35, C35, and D31 in Division 5. Corrective action: The company ensure that procress water level, water table and subsidence on peat will be represent for all peat depth, and the company will be monitored periodically. Auditor Conclusions: Closed Verification result: During the 2nd surveillance audit the company already conducted the water level measurement for all peat loacation on the field. Example on field number 35 Division 2, based on record water level meas-urement is still on standard. Overall result water measurement no indicated that that the water level is below than standard, and the company has efforts to maintain water level when the weather is not sup-ported such as dry season.

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Date of closure: September 4 th, 2013

Criterion 4.4.2 (Minor) Monitoring of effluent BOD

NCR No. 2013 – 8 of 29 ; Major The company still not conducted of analysis and problem identification for result of monitoring water quality analysis, because the result is more than the standart required (NCR. 2011 – 27 of 34 ) raise again as a non conformities. Correction: The company has analyze and identification for water quality analysis result. Based on record of problem indentification on July 20, 2013. From the problem identification showed that the root cause analysis is there is no identified the the problem, because the upstream the river is not in the area’s company but it so far from the company, and the company not dispose they waste water in to the environmental, but the company use the waster water for land application and the location is so far from the river. The company still conduct the water analysis periodically to ensure and maintain the quality of the water. Corrective action: The company has commitement to conduct the water analysis in the river a crossed they area to moni-tor and maintain the water quality. Auditor Conclusions: Closed Verification result: During the 2nd surveillance audit, the company has conduct identification of root cause about water quality analysis. Accordance to the report, the upstream of river Brasau is located far from the estate. But, the company have commitment to analyzed the water quality for this river. Also, estate and mill no release ther POME to the river, but use for land application. Based on testing result of water quality conducted by Environmental Quality Control Laboratory, PDAM Tirtawening Kota Bandung, for Brasau river in upstream and downstream. Testing result number 4.751.304.027 (for downstream) and 4.751.304.028 (upstream) all of paramaters (30 paramaters) analyzed date on Juni 12 – 30, 2014, based on Government Regulation Number 82/2001 is complie with the standart. Date of closure: September 4 th, 2013

Criterion 4.5.1 (Major) An IPM plan is documented a nd current

NCR No. 2013 – 9 of 29; Major There is no found the record handling of Ganoderma attack in Division II. Because if refer to early warn-ing system record, the attack is high rate Correction: The company has submit correction for handling of Ganoderma attack with program for Genoderma at-tack control and work program to monitoring (census/early warning systems) and inventarization of loca-tion for Genoderma and isolated the infected area. The company a record of document for control of Ge-noderma attack in Division 2 on August 2013 until July 2014, when the process of control such as: cen-sus for location infected; mapping infected area; action (isolated for infected area, hand picking and burn). Corrective action: The company will be ensure that Genoderma attack will monitored by the early warning system and ensure the infected area should be isolated, and will be conduct gradually. Auditor Conclusions: Closed

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Verification Result: The company already census for Ganoderma attack, example for ganoderma census for Divison VI in 2013, it was recorded 1,254 attacked by Ganoderma with :

- low attacked as 222 tree - medium attacked 429 tree - heavy attackec as 603 tree

until during the 2nd surveillance audit, the company already handled, with hand picking and burning the ganoderma mushroom, evidenced by photograph and census record. Until June 2014, the company also conduct the ganoderma census. Date of closure: September 4 th, 2013

Criterion 4.6.1 (Major) Evidence of use of only app roved and registered agrochemicals permitted by the relevant authorities

NCR No. 2013 – 10 of 29 1. There is found that the chemical in the estate does not have recommendation licensed from Labour

and Transmigration Head Offices (related to CR 2.1) 2. There is no found the record for company commitment to reduce/elimanate the chemical on 1A and

1B WHO and Rotterdam Convention (raise again as a non conformities) Correction: 3. The company has already submit letter number 384/PRSN-BSP/JBI/VIII/2013 on August 2nd, 2013

about request for registered of chemical used in work place to Head Offices of Labour and Transmi-gration of Tanjung Jabung Barat Regency, and has receipt evidence on August 04, 2013.

4. The company has policy for reduce of chemical in type of 1A and 1B WHO and Rotterdam Conven-tion, was issued on August 1st, 2013.

Corrective action: 5. The company has already delivered letter for registered they chemical used and ensure that all chem-

ical in the company was registered in Pesticides Comission Book and Head of Labour and Transmi-gration of Tanjung Jabung Barat Regency

6. The company has commitmen for reduce/eliminate of chemical used from type of 1A and 1B WHO and Rotterdam Convention from each activity, and when during the audit the company showed that they was reduced gradualy by the evidence of realization of chemical used and purchased of chemi-cal in 2013.

Auditor Conclusions: Closed Verification Result: Company oly use registered pesticides in Pesticides Comission Book and Head of Labour and Transmi-gration of Tanjung Jabung Barat Regency . There is policy to reduce reduce/eliminate of chemical used from type of 1A and 1B WHO and Rotterdam Convention from each activity, and when during the audit the company showed that they was reduced gradualy by the evidence of realization of chemical used and purchased of chemical in 2013. Date of closure: September 4 th, 2013

Criterion 4.6.2 (Major) Records of the results of h ealth check-up for those who apply agrochemi-cals

NCR No. 2013 – 11 of 29: Major 1. The Company has no proof of re-checking relevant worker who suffer breathing difficulties, lung tu-

berculosis and have cholinesterase level exceed and send them for further medical check program to ensure that they need further treatment, as presented at improvement of the NCR No.2011-14 of 34 (previous aud it)

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2. The company has no medical checkup periodically for all workers who related with agrochemicals for 2012

Correction: 1. Through the letter memo number 469/PRSN-BSP/JBI/IX/2012 on September 1st, 2012 to Estate

Head about the followed of medical chekup for workers from Division 6 and Division 4 from the HRD Team Leader. Then, the Estate Head was followed the memo by letter memo number 159A/EH-INTI/IX/2012 on September 15, 2012 about the followed of medical checkup result. Based on infor-mation from the memo, the workers are no longger work in the company, because the workers refuse to replace they work from the chemical work to manual work.

2. The company has carry out of medical checkup in 2013 for all workers evidence byrecord the result of medical checkup in 2013 and photograph.

Corrective action: The company will be ensure and consistent about the medical check up realization periodically for future. Auditor Conclusions: Closed Verification Result: Company already identify pollution and emission sources in whole company activities, mitigation program al-ready defined and brief to all related section and parties. Some of sign board related this issue has been in place accordingly Date of closure: September 4 th, 2013

Criterion 4.7.3 (Minor) A documented risk assessmen t for Occupational Health and Safety (OHS)

NCR No. 2013 – 12 until 16 of 29: Minor 1. Was found that the workers not used the PPE when they work especially for work in altitude more

than 2 metters. 2. There is no found of risk assessment for temporary actvities in the company Correction: 1. The company has a letter for commitment on Monday July 1st, 2013 in 10.00 AM, was held in meet-

ing room of contractor (PT RMM), and the contarctor willing to follow of law and regulation about health and safety, and was sign on July 18, 2013 and equipped with photograph the PPE used by workers.

2. The company has job safety analysis for temporary activities such as: dredging POME ponds, sludge disposal from POME ponds, roof replace on the mill, welding, fabric painting.

Corrective action: 1. The company will be ensure that all of they contractor should be abide law and regulation about

health and safety, also the company make socialization for contractor workers before they start the work and ensure they PPE’s is complete.

2. The company was ensure all temporary activities in the company was include on the job safety analysis and make sure the job safety analysis is applied

Auditor Conclusions: Closed Verification result:

1. Company already renewing the Risk Assessment included work in altitude more than 2 meters. This policy already brief to third party like contractor and other temporary working in company.

2. Risk assessment for other temporary working already defined and add in into company risk assess-ment

Date of closure: September 4 th, 2013

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Criterion 4.7.2 (Minor) Regular health examination by a doctor for workers in station or exposed to high risk work

NCR No. 2013 – 14 of 29; Major There is no record for regular health examination for 2 operators in enginee room in November 2011 (NCR No. 2011 – 16 of 34 raised again as non conformities) and the same record in 2012. Correction: The company has carry out the regular health examination for 2 operators in enginee room evidence by the result of medical checkup for all workers in 2013 and photograph. Corrective action: The company has a commitment to ensure that operator in enginee room will always be included in regular health examination periodically in the future. Auditor Conclusions: Closed Verification Result:

1. Company has perform medical examination for all engine room operators and the record are kept, All follow up action already taken as well

2. Medical examination record 2013.. Date of closure: September 4 th, 2013

Criterion 4.8.1 (Major) A documented training progr amme for staff, employee and scheme smallholders in accordance with workers’ positions and competences

NCR No. 2013 – 15 of 29; Major There is not found the training program and realization for smallholders Correction: The company has program for smallholders training in 2013 incorporated into 12 cooperation (KUD) when the topic in training discuss about manual handling, fertilizer application, IPM, production and harvesting, and open discussion. Corrective action: Company ensure that program will be carry out very well and documented. Auditor Conclusions: Closed Verification Result: Company has training program for year 2014, some of program already executed and record was maintained. For smallholder traiing conducted for the agriculture best practice done and recorded. Date of closure: September 4 th, 2013

Criterion 5.2.2 (Major) If, rare, threatened or end angered species, or high conservation value habitats are present, appropriate measures to prese rve them are to be taken.

NCR No. 2013 – 16 of 29: Major Theres no found impelementation record of management plan HCV especially for monitoring, measure-ment, preserve and protection (NCR No. 2011 – 21 of 34 ) raise again as a non conformities Correction: The company has conduct of spesies monitoring in the HCV area, based on record of monitored the con-

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dition of species was good and equipped with photograph, also the company has commitment for protect all the species in the HCV area Corrective action: The company make efforts to followed and realization the HCV management gradually, and ensure all the HCV management plan will be implemented periodically. Auditor Conclusions: Open raised as Non conformitie s for year 2014 Verification result: The company not yet conduct monitoring, measurement, preserve for flora and fauna included to IUCN and CITIES appendix II accordance to HCV report. Raise again as non-conformities. Date of closure: September 4 th, 2013 Criterion 5.2.1 (Minor) Posters and signs warning o f the presence of protected species are to be produced, distributed, and made visible to all work ers and the community, including guidelines in handling them NCR No. 2013 – 17 of 29: Major There is no found signboard was installation in the housing, mill and others area (NCR No. 2011 – 22 of 34) raise again as a non conformities Correction: The company has put the signboard in the housing, mill, office and others area. And the signboard was in-form about the prohibition for illegal hunting, illegal fishing, illegal logging, and high risk area for burn, chemist application. Corrective action: The company has commitmen for maintainance and monitored all the signboard was install and will be add a new signboard if need for new location. Auditor Conclusions: Closed Verification Result: During the 2nd surveillance, the company already installation HCV signboard for all housing about not allowed for hunting, burning, catching, chemical activity and all of activity will be danger for HCV area. Date of closure: September 4 th, 2013

Criterion 5.2.2 (Minor) Companies are to appoint de dicated and trained officers to monitor any plans and activities as above

NCR No. 2013 – 18 of 29; Major Company has assign the HCV PIC for manage the HCV area, but the person have no yet training for HCV (NCR No. 2011 – 23 of 34 ) raise again as a non conformities. Correction: The company has assign of the HCV PIC by the vidence is certificate of Technical training assess-ment of HCV Value Area on 4 – 8 April, 2011 which focus to manage and ensure that HCV area is al-ways protect from illegal activites and to increase the HCV value in the area. Corrective action: The company ensures that the PIC of HCV area carry out and maintenance the HCV management plan. Auditor Conclusions: Closed

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Verification Result: During the 2nd surveillance, the company already training for HCV responsible person on April 4-8, 2011. And this person responsible for HCV management , evaluation of HCV management implemen-tation, and others. Date of closure: September 4 th, 2013

Criterion 5.6.1 (Major) Evidence of identification of pollution and emissions sources at mills

NCR No. 2013 – 20 of 29: Major List of identification pollution and emission of the company still not covered all activities Correction: The company has list of identification pollution and emission for all activities contribute to GHG by the record of identification of environmental aspects and impacts, such as: is peat land on the area, fossil fuel, land clearing fertilizer application and etc. Corrective action: The company ensure that all of activites contribute to GHG emission was put in to list of identification pollution and emission Auditor Conclusions: Closed Verification Result: Company already identify pollution and emission sources in whole company activities, mitigation program al-ready defined and brief to all related section and parties. Some of sign board related this issue has been in place accordingly Date of closure: September 4 th, 2013

Criterion 5.6.2 (Major) Monitoring of pollution and emission quality of the sources identified

NCR No. 2013 – 21 of 29: Major There is no found evidence of realization to monitoring and mitigation for GHG Correction: The company has list invetarization of GHG emission from the estate and mill activities within in 3 years period. Corrective action: The company has commitment to monitor the emission quality from the emission source and pollution was produce from the astate and mill activites such as FFB transport, heavy equipment, EFB application, fossil fuel, genset housing, within 3 years period. For the monitoring of emission and poillution the com-pany will be conduct the emission analysis. Auditor Conclusions: Closed Verification Result: During the 2nd surveillance, the company already conduct the emission monitoring program through the emission analysis in every semester, evidence by:

- Testing result report number 4.751.303.030 and 4.751.303.029 for boiler emission analysis, anal-ysis date on Juni 12 – 30, 2014, based on regulation of Environmental Ministry Number 07/2007. Accordance to testing result all paramater compliance with the regulation. Testing conducted by Environmental Quality Control Laboratory of PDAM Tirtawening, Bandung.

- Testing result number 4.751.303.031 and 4.751.303.032 for Genset emission analysis, analysis

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date on Juni 12 – 30, 2014, based on regulation of Environmental Ministry Number 07/2007. Ac-cordance to testing result all paramater compliance with the regulation. Testing conducted by En-vironmental Quality Control Laboratory of PDAM Tirtawening, Bandung.

- Testing result number 4.751.303.028, 4.751.303.026, 4.751.303.024, 4.751.303.025, for ambient air, sampling point in office area, guest house, loading area, village border, analysis date on Juni 12-30, 2014, based on regulation number: PP 41/1999, KepMen LH number Kep-50/MENLH/11/1996, KepMen LH number Kep-49/MENLH/11/1996. Accordance to testing result all paramater compliance with the regulation. Testing conducted by Environmental Quality Control Laboratory of PDAM Tirtawening, Bandung.

Date of closure: September 4 th, 2013 Criterion 6.1.1 (Major) Documented environmental an d social impact assessment, including de-tails of positive and negative social effects that may be caused by plantations and mills, and documented participation of affected parties and lo cal communities NCR No. 2013 – 22 of 29; Major There is no found report of management and monitoring of social impact assessment was included the negative impact from the company activities Correction: The company has report of management and monitoring of social impact assessment was included the negative impact from the company activities for periode of January – Juni 2013 with 3 negative impacts was identified on the report. Corrective action: The company will be ensure, all of the negative impact based on SIA and EIA document will be moni-tored periodically. Auditor Conclusions: Closed Verification result: Company has management plan 2013 for monitoring, evidence of social impact assessment was includ-ed the negative impact from the company activities. Measurement and monitoring will be conducted an-nually. Date of closure: September 4 th, 2013

Criterion 6.1.1 (Minor) Regular monitoring and mana gement of social impact, with the participa-tion of local communities

NCR No. 2013 – 23 of 29; Minor There is no found record of management and monitoring of social impact was accepted by all stake-holders Correction: The company has matrix for social impact management plan with the participation of the local commu-nities evidence by minutes meeting between companies management with local communities, when the local communities has signed Corrective action: Documentation for social impact management plan with participation of the local communities. Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next audit. Date of closure: September 4 th, 2013

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Criterion 6.2.1 (Major) Documented procedures and r ecords of communication and consultation with the communities.

NCR No. 2013 – 24 of 29: Major There is no found record documentation of SOP consultation and communication was accepted by the affected communities Correction: The SOP communication and consultation has involve the communities and others related stakeholder by the evidence of list of signed about the socialization and transfer of procedur number AG-SM-R-24 about communication and consultation to communities and local village government. Corrective action: Ensure that all of procedure related to consultation and communication to communities and related stakeholders should be accepted together Auditor Conclusions: Closed Verification result: It was sight SOP communication and consultation was communicated to relevant stakeholders, during the audit it was observed list of stakeholder from Purwodadi village and dasal village signrd the reciving notes of procedure number AG-SM-R-24 about communication and consultation to communities and local village government dated September 4, 2013 Date of closure: September 4 th, 2013

Criterion 6.3.1 (Major) An open system, which is ac cepted by affected parties, to receive com-plaints and to resolve dispute in an effective, tim ely and appropriate manner

NCR No. 2013 – 25 of 29; Major There is no found that the mechanism of grievence was accepted by the affected communities Correction: The company has mechanism of grivence and conflict resolution, and also has accepted by the com-munities and related stakeholders evidence by list of signed socialization and transferred the procedure AG-SMM-P-S-02 to all communities such as Village local government, cooperation, Head of Village, etc. Corrective action: Documentation for mechanism of grievence and conflict resolution and ensure that all of the problem related to grievence and problem resolve is refer to this SOP and should be documented. Auditor Conclusions: Closed Verification Result: It was sight SOP communication and consultation was communicated to relevant stakeholders, during the audit it was observed list of stakeholder from Purwodadi village and dasal village signrd the reciving notes of procedure number AG-SMM-P-S-02 about communication and consultation to communities and local village government dated September 4, 2013 . Date of closure: September 4 th, 2013

Criterion 6.5.2 (Minor) Agreements entered into wit h contractors are to specify that contractors abide by labor laws

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NCR No. 2013 – 26 of 29; Minor There was found on the SPK (letter agreement for contractor) not consistent about the compliance of labour law and regulation Correction: The company has revised their letter of agreement to contractor related to compliance of law and regu-lation example on letter of agreement on June 5, 2013 in clause 9.4 was state the contractor should be compliance to law and regulation. Corrective action: The company ensure that all of letter agreement, that the contractor should be compliance to law and regulation. Auditor Conclusions: Company define and implement new letter agreement that require to suppliers and contractor comply to regulation like SPK No. 021/SPK-AMM/VI/2014 between PT Agro Mitra Madani with CV Fadhilla, for service power pack presson Date of closure: September 4 th, 2013

Criterion 6.11.1 (Minor) Records of company contrib utions to the local development

NCR No. 2013 – 27 of 29: Minor There is no found record of realization for CSR program related to company contributions Correction: The CSR realization is not based on budget, but it is depand of initiative and realistic from the company Corrective action: The company ensure that all of CSR realization should be documented Auditor Conclusions: Some of CSR program already executed such as maintenance of access road of smallholder to sukadamai Village medio April 30th, 2014 Date of closure: September 4 th, 2013

RSPO Certification Requirement No 4.2.3

NCR No. 2013 – 29 of 29 There is no found the program and realization for smallholder certification process preparation. Correction: The company has submit the smallholders program, the content was inform about the RSPO introduc-tion and best practice training for palm oil. Corrective action: The company has a commitment to certify they smallholders through the smallholders certification pro-gram. Auditor Conclusions: Closed Company provide minutes meeting relating socialization of smallholder program to cooperation in Pur-wadadi village dated on September, 4 2014.

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Date of closure: September 4 th, 2013

3.3 Identified Non-conformance, Corrective Actions Taken and Auditor Conclusions During the 2nd surveillance audit, a total of 4 nonconformances were identified. These consisted of 2 major non-conformities and 2 minor non-conformities, and 2 raise again as a non conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the assessment, and this was verified by the audit team through document that submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the clo-sure of these minor non-conformities will be assessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

Criterion 2.1.1 (Major) Evidence of compliance with relevant legal requirements

NCR No. 2014 – 01 of 04 The company has applied for registration of the use of chemicals at work on August 2, 2013 by letter No. 384 / prsn - BSP / JBI / VIII / 2013, but up to the implementation of surveillance -2 showed the company could not attempt to obtain consent on the use of these chemicals in the workplace Correction: Company already get permit for of chemicals at work on August from Office of Labor District Tanjung Jabung Barat Corrective Action: Company has a plan for following action regarding permit and regulation fulfillment. Auditor Conclusions: Closed Verification result; Company provide evidence Company already get permit for of chemicals at work on August from Of-fice of Labor District Tanjung Jabung Barat Date of closure: September 06, 2014.

Criterion 2.1.2 (Minor) A mechanism for ensuring th at compliance with relevant legal requiremen-tis implemented

NCR No. 2014 – 02 of 04 The company can no showed the mechanism/program to fulfil the 19 law and reagulation is still no compli-ance based on record of law and regulation evaluation. Correction: The company arranged a program for law and reagulation compliance, and make list of law and regulation is still non compliance. Corrective Action: The company ensure that program through the evaluation periodically to identified the law and reagulation if there are still no/or progress of compliance. Auditor Conclusions: Evidence of corrective action plan accepted. Effectiveness of implementa-tion to be verified at next audit

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Criterion 4.1.2 (Minor) Record of operational resul ts

NCR No. 2014 – 03 of 04 It found two precedures of grading Form.No.AG-SMM-WI-L-02 Rev04 (obsolete) mentioned about grading should be throung 100 sample of FFB, and Form.No.AG-SMM-WI-L-02 Rev06 (valid) mentioned about every truck from own estate and smallholder should be sample. When the checking on the loading ramp, grading officer still conduct the grading process referenced to procedure obsolete. Correction: The company has reviewed again they procedure, and has approved the new procedure number AG-SMM-WI-L-02 Rev 07, and determined the procedure related grading except that procedure is obsolete. Corrective Action: Conducted reviewed of all company procedure to ensure the validity all of procedure and realization on the field. Auditor Conclusions: Evidence of corrective action plan accepted. Effectiveness of implementa-tion to be verified at next audit

Criterion 5.2.2 (Major) If, rare, threatened or end angered species, or high conservation value habi-tats are present, appropriate measures to preserve them are to be taken

NCR No. 2014 – 04 of 04 The company already conducted HCV management, but on the record can no showed record of monitoring and measurement of flora and fauna as mentioned on HCV report (CITES Appendix II and IUCN). This is raise again as a non-conformities. Correction: The company has conducted and recording of monitoring result and measurement of flora and fauna based on HCV report. Corrective Action: Conducted monitoring periodically of flora and fauna based on HCV report. Verification result: The company has submitted the record of monitoring and measurement of flora and fauna based on HCV report in September 2014. On the report mentioned the location for monitoring based on HCV, i.e.:

- Conservation block in filed number B03 - Water catchment area in division 3 - Giring-giring river - Field number A09 – A49, B11, B12, B13 – B45, division 1, 2, 3 and 5 - Springwell in D09, D05 – D09, C05 – C09 dan B05 – B09) division 4 - Springwell in B04, B04 – B12, A09 – A10 dan A12, division 3 - And others

Auditor Conclusions: Closed

3.4 Description of Supply Cahin Management System During the 2nd surveillance of RSPO SCCS audit, PT Agro Mitra Madani Palm Oil Mill is producing crude palm

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oil (CPO) and palm kernel (PK), mill has register on RSPO E-trace System, but for their transaction in the RSPO E-Trace System not register yet, because company currently sell their product without claiming it as certified sustainable palm oil (CSPO) or certified sustainable palm kernel (CSPK), all CPO produced from PT Agromitra Madani Mill are sold as regular product. However according to explanation from mill manager, the company will follow all requirements from RSPO to support implementation of sustainability requirements. There are two source of FFB supply based in PT AMM Mill, first; from own estate when in 2013 FFB receiving total is 40.10% or 96,811 tonnes, with CPO production is 18,044 tonnes and PK production is 3,939 tonnes with OER realization is 21.23% for CPO and 4.87% for PK. Second; from outgrowers (smallholders) with FFB receiving is 59,47% or 143,586 tonnes. During 1st surveillance record data until July 2014, PT AMM Mill re-ceived the FFB from own estate is 44,967 tonnes or 30.50% and from outgrowers (smallholders) is 78,442 tonnes or 53.21%. The company implement SCCS-RSPO with model “Mass Balance” model. The following is a description of the company’s supply chain management system according to the RSPO SCCS requirements, including status of compliance of the company and their outsourced third parties to RSPO SCCS requirements. The description of supply chain management system as determined below :

1. Documented procedures

Findings: The company has list of procedures for incoming FFB until product dispatch, currently company imple-ment Quality Management System ISO 9001: 2008, all procedure incorporated in company together with procedure for receiving order available in sales department and mill. The example procedures is:

- AG-SMM-P-L-01 about unit transport checking to ensure the contamination - AG-SMM-P-L-07 about information confirmation to certification body for over production - AG-SMM-FC-L-01 about flowchart inspection on incoming material - AG-SMM-WI-L-25 about work instruction fro FFB certified and non certified verification - AG-SMM-FR-P-01 about delivery order - AG-SMM-FR-P-11 about daily report - AG-SMM-FR-P-13 about production report and delivery - AG-SMM-FR-P-14 about weighing slip - AG-SMM-FR-P-15 about dispatch slip - AG-SMM-FR-P-16 about “nota timbang kosong” and delivery sampling

Based on field observation, person in charge in weighbridge understood for handling and received raw ma-terial/FFB certified and non-certified. Also in loading ramp area, grading officer also knowing about han-dling raw materil certified by the marking (stamp) on FFB received slip. PT AMM Mill assigned person who responsible with SCCS implementation by letter number 109.B/AH-BSP/JBI/VIII/2012 issued by Area Head on August 31, 2012. On the letter also mentioned about duties and responsibilities of SCCS Management Respresentative, such as: to control of procedure and SCCS implementation; coordinate with CB about over production, and others. PT AMM Mill has documented procedure for receiving and processing certified and non certified FFB's through the delivery slip from home grown will be stamp by CSPO stamp, and for others (except) home grown the slip deliver will not use stamp. This is was explained in organization procedure, i.e.:

- Form.No.AG-SMM-FC-L-01 Rev04 date issued July 20, 2013 about checking on FFB receiving in mill. On the flowchart of receiving FFB mentioned QC Asst and clerk weighing responsible for verification of FFB certified and non certified thorugh the "nota timbang" weighing slip of FFB transport (AG-SMM-FR-E-25). Also, they are responsible for daily report of FFB certified and non certified (AG-SMM-FR-P-11).

- Form.No.AG-SMM-WI-L-25 Rev00 date issued July 20, 2013 about " perintah kerja verifikasi TBS sertifikasi dan non sertifikasi". Work instruction mentioned about: every incoming material should be check of delivery notes/slip to ensure that all of delivery slip there is a stamp or not; split of de-livery slip with stamp and non-stamp.

In field (loading ramp area) and weighing location, organization have verified and split for delivery slip with stam and non-stamp, and also in loading ramp organization also split grading for home grown grading. Compliance status: Compliance

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2. Purchasing and goods in

Findings: PT AMM Mill has documented receiving FFB certified and non certified and documented all of FFB certi-fied from incoming material process, grading in loading ramp process and recorded in daily report every day. Also, mill has mechanism to inform the certification body about over production projection through the pro-cedure AG-SMM-P-L-07 about information confirmation about over production. Until the 1st surveillance audit, there is no over projection based on record of production in 2013, also the mill has decides will im-plemented of Mass Balance model for RSPO SCCS. And until during the 1st surveillance audit, the mill has no claimed yet any palm oil as RSPO SCCS certified. Compliance status: Compliance

3. Records Keeping

Findings: PT AMM Mill has mechanism for control and maintenance all of data and document related to the SCCS, through the procedure number Form.AG-SMM-P-L-01 with retention time all of data and document in 5 years. During the 1st surveillance audit there is no record data related to SCCS, because the mill no claimed yet the RSPO SCCS certified product. But for incoming material from own estate, in weighbridge slip completed by SCCS stamp, and mill has commit to keep the record for 5 years. Mill has record of mass balanced for palm oil product certified and non-certified. In 2013, CPO certified recorded until December 2013 is 18,044 tonne and 3,939 tonne for PK certified. On the record of SCCS simulated, example in sales document for CPO to Wilmar Nabati ticket number 20140800198 Doc. Number 158/DO-CPO-AMM/VII/14, dated on 11/08/2014 with netto total sale is 22,310 mt, and contract number also available, DO number, quality product (FFA, water content, Dirty), unit num-ber transport, and CSPO stamp also available with Mass Balanced model explained. For procuduction activities in mill, there is no outsourcing activity. Compliance status: Compliance

4. Sales and Good Out

Findings: Based on record of sales document, example for CPO ticket number delivery 20140800198 Doc.Number 158/DO-CPO-AMM/VII/14 dated on 11/08/2014 there is no buyer addres, also on delivery CPO ticket number there is no date of invoice issued. On the other hand, delivery CPO ticket number was explained about product description such as FFA, wa-ter content, dirty, also SCCS model “Mass Balanced” are available. For related refferenced documentation such as DO number, Doc.number, minutes of CPO delivery and other also available in sales document. Compliance status: Non Compliance NCR No. 2014 SCCS 01 of 02 On the sales document of CPO delivery to Wilmar Nabati, with ticket number 20140800198, Doc Number 158/DO-CPO-AMM/VII/14, date on 11/08/2014 (for SCCS simulation), there is no buyer addres and date of invoice issued.

5. Training

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Findings: PT AMM mill has conducted SCCS training for related person to implemented of SCCS, but, it was found two (2) person in weighbridge room have not SCCS training, while they was working in wheibridge room in 4 years. Compliance status: Non Compliance NCR No. 2014 SCCS 02 of 02 Organization did no provided the training for all staff required to implementation of SCCS, because it was found 2 person weighbridge clerk, they don’t have SCCS training.

6. Claims

Findings: The company has specific SOP for making claims regarding the use of or support of RSPO certified oil palm products product according RSPO communication and claims. The implementation of SOP is after company get order for certified palm oil or palm kernel. Compliance status: Not applicable at this time

3.5 Status of Previously Identified Non-conformitie s SCCS Non-conformance 2013-SCCS-01 of 08: There is no assign person who has responsibility and autority over the implementation of SCCS requirements. Correction : Management representative to ensure compliance with SCS requirement has been assigned. Corrective Action: To impement SCCS requirement as well as needed according to job description and responsibilities. Date of closure : August 31, 2013 Verification result: Company provide assignment letter No. 109.B/AH-BSP/JBI/VIII/2012 regarding assignment Mr. Hartanto as SCCS representative for ensuring SCCS implementation and SCCS compliances Auditor Conclusions: Closed SCCS Non-conformance 2013-SCCS-02 of 08: Both procedures for receiving and processing still not inform about mechanism for receiving certified and non-certified FFB neither processing certified and non-certified FFB. Correction : Company made procedures for receiving and processing for certified and non-certified FFB G-SMM-FC-L-01. Company will implement Mass balance according to the nature of FFB suuplied to PT Agro Mitra Madani. Corrective Action: To implement the relevant procedure consistently.

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Date of closure : July 20,2013 Verification result: Company provide new working instruction regarding Incoming FFB in Agromitra Madani Mill as deter-mined on Form AG-SMM-FC-L-01 issued on July 20, 2013, the working instruction explain about receiv-ing certified and non-certified FFB neither processing certified and non-certified FFB. Auditor Conclusions: Closed. SCCS Non-conformance 2013-SCCS-03 of 08: There is no information about certified status in all incoming FFB documents and company has no mech-anism to verify incoming certified FFB and non-certified FFB Correction : Certified status will be put in all incoming FFB documents. Company made mechanism to verified incom-ing certified and non certified FFB as determined on AG-SMM-WI-L-25 Corrective Action: To implement the relevant procedure consistently according to SCCS requirement. Date of closure : July 20, 2013 Verification result: Company provides working instruction regarding guidance for marking and put identification about certifi-cation status in all incoming FFB document to distinguish between certified and non-certified, as deter-mined on AG-SMM-WI-L-25. Auditor Conclusions: Closed SCCS Non-conformance 2013-SCCS-04 of 08: The facility shall inform the CB immediately if there is a projected overproduction Correction : Company made procedure regarding how to communicate to the certification body if there is a projected over production as stated on AG-SMM-P-L-06 Corrective Action: To implement the relevant procedure consistently according to SCCS requirement. Date of closure : July 20, 2013 Verification result: Company provide new procedure regarding communication to certification body if there is a overproduc-tion projected as determined on AG-SMM-P-L-06 issued on July 20, 2013. Auditor Conclusions: Closed SCCS Non-conformance 2013-SCCS-05 of 08: There is a procedure for records keeping i.e. AG-SMM-P-L-01, however the retention time for records keeping only 2 years instead of 5 years. Correction :

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Revise the records control procedure and require retention time for all relevant records into 5 years, as determined on AG-SMM-P-L-01, 14,15 dan 16 Corrective Action: To implement the relevant procedure consistently according to SCCS requirement. Date of closure : July 22, 2013 Verification result: Closed Auditor Conclusions: Company provide procedure AG-SMM-P-L-01 14,15 dan 16, for records keeping and found information that all relavant records for SCCS imlemntetaion wil be keep maintained for 5 years period. SCCS Non-conformance 2013-SCCS-06 of 08: There is a record of material balance; however information on material balance is not included about product dispatch report. Only state incoming FFB and processing including quantity of product. Correction : Information about produc dispatch has been included on daily production records form AG-SMM-FR-P-13 and Form AG-SMM-FR-P-11 dan Form AG-SMM-FR-P-13 as attached. Corrective Action: To Implement production report (AG-SMM-FR-P-11) and Form No(AG-SMM-FR-P 13) as required. Date of closure : July 20, 2013 Verification result: Company provide revised material balance the new material balance has been inform about quantity of incoming material and FFB processing with daily basis, as recorded on Daily production report with Form No. AG-SMM-FR-P. 11Rev. 01 this record covering production processing for palm oil and palm kernel product. Auditor Conclusions: Closed SCCS Non-conformance 2013-SCCS-07 of 08: PT Agromitra Madani has not included selected supply chain model in all sales documents. Correction : All sales document format has been revised to include information about selected supply chain model i.e Mass Balance. Corrective Action: To impelement the new format consistently accoridong to requirement. Date of closure : July 20, 2013 Verification result: Company provide revised format for delivery document such as: delivery order; delivery evidence; deliv-ery note, and weigh bridge ticket. All documents already indicate selected supply chain model with MB stamp. Implementation will be start after company get carried CSPO/SCPK order. Auditor Conclusions: Closed

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SCCS Non-conformance 2013-SCCS-08 of 08: The facility shall provide the training for all staff as required to implement the requirements of the Supply Chain Certification Systems.

Correction : Training for SCCS was provide to relevant staff by exernal consultant AFI-ERFOLG Corrective Action: All relevant training will be provided to improve competency as required. Date of closure : August 20, 2013 Verification result: Company provides training evidence such as lit of participants, photograph and minutes training. Training was conducted on August 20, 2013. Auditor Conclusions: Closed

3.6 Identified Non-conformance against RSPO SCCS re quirement, corrective actions taken and auditors

conclusions SCCS Non-conformance 2014-SCCS-01 of 02 On the sales document of CPO delivery to Wilmar Nabati, with ticket number 20140800198, Doc Number 158/DO-CPO-AMM/VII/14, date on 11/08/2014 (for SCCS simulation), there is no buyer addres and date of invoice issued. Correction : Organization has requested for address supplier (buyer address) added on IT Desk corporate, so that when the sales document issued, the buyer address will be automatically include on the sales document. Corrective Action: Ensure that all of sales document of CPO delivery and others delivery certified product has been compli-ance with RSPO SCCS requirement. Date of closure : September 5, 2014 Verification result: Organization submitted CPO deliver sample document with included the buyer address, with ticket num-ber 20140900476, with name of buyer is PT Musim Mas and complete with the address. Auditor Conclusions: Closed SCCS Non-conformance 2014-SCCS-02 of 02 Organization still not provided training for all staff required to implementation of SCCS, because it was found 2 person weighbridge clerk, they don’t have SCCS training. Correction : MR has been conduct coordination with corporate about training program will be conducted on Septem-ber 2014. Corrective Action: Arranged the training program and also internal traning and refreshment.

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Date of closure : September 5, 2014 Verification result: The company has send employee for training progam for SCCS training. Auditor Conclusions: Closed.

3.7 Noteworthy Positive Components

Criterion 8.1.

Findings: Company commitment for RSPO compliance still good, even financial condition for recent one year is not good.

3.5 Issues Raised by Stakeholders and Findings Pert aining to Issues Below is a summary of issues raised by stakeholders interviewed on-site

No. Issues Raised Management Response Audit Verification

1.

There is no CSR program for community in year 2012 to 2013

Due to finacial condition all CSR program being postponed and will be reschedule after recover condition.

No CSR program evi-dence for year 2012

2. No training provide for smallholder

Due to finacial condition all train-ing program being postponed and will be reschedule after recover condition.

No training evidence for year 2012

3. Company payment for FFB still toleranced

Company will try the best for payment FFB from smallholder.

Some delayed but it was tolerance by the smll-holder.

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4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL RESPONSIBILITY

4.1 Date of Next Surveillance Visit

The next surveillance visit is planned for July 2015

4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client

It is acknowledged that the assessment visit was carried out as described in this report and we accept the as-sessment findings and report content. Signed on behalf of Bakrie Sumatra Plantation Unit Jambi

…………………………………………. Efdy Ruzali Manager Representative Date: November 24, 2014

Signed on behalf of PT TUV Rheinland Indonesia

…………………………………………. Dian Susanty Soeminta Lead Auditor Date: September 5, 2013

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APPENDICES

Appendix 1: Details of Revised Certificate No applicable

Appendix 2: List of Abbreviations AMDAL Analisis Dampak Lingkungan & Sosial

(Social & Environmental Impacts Assessment) CPO Crude Palm Oil EIA Environmental Impact Assessment ERTs Endangered, Rare & Threatened species ESH Environmental Safety & Health FFB Fresh Fruit Bunches EFB Empty Fruit Bunches HCV High Conservation Value IPM Integrated Pest Management LTA Lost Time Accident MSDS Material Safety Data Sheets NGO Non-Government Organization OSH Occupational Safety & Health PKO Palm Kernel Oil POME Palm Oil Mill Effluent PPE Personal Protective Equipment RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SIA Social Impact Assessment SOP Standard Operating Procedure UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pengelolaan Lingkungan (Environmental Management Efforts)

Appendix 3: List of Stakeholders Interviewed and Co ntacted

No. Name of Stakeholder

Institution - Address Remark

Stakeholders Interviewed On-Site 1. Kasman Ardi HRD 2. Ahmad Purchasing section 3. Supandi HRD 4. Ade Perdana Officer 5. Hasan S. Lubis Agro Mitra Madani 6. Hartanto ISO section 7. Irwin Syarif Smallholder 8. Ridwan Utility 9. Amir Hasan Agro Mitra Madani 10. M. Padhirx Purchasing 11. Sunadi Head Office Jambi 12. Ahmad Fuad PBSN 13. Triadi Agro Mitra Madani 14. Harsono Kasino 15. Zulnofirman Agro Mitra Madani 16. Najmul Manar HO (Head Office) 17. Jasmin Mill Agro Mitra Madani

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Appendix 4: Observations and Opportunities for Impr ovement

No. Observations / Opportunities for Improvement Criteria 1.

Simulation of emergency and response procedure for plantation according exist-ing SOP should be conducted to demonstrate adequacy of SOP. (5.5)

5.5

2. Water pump not available especially in plantation division office, this is very dif-ficult to find water without water pump during emergency condition.

5.5.

3. Replacement program of mask filter for spraying is not available 4.7

4. Communication about working agreement only by formal method, sometime this is not effective especially for field worker.

6.5